30 April 2018 Comfort Letter — Foreign spin-off – prescribed distribution
Miscellaneous administrative policy
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GST/HST Interpretation
22 December 2020 GST/HST Interpretation 209955 - – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […]
22 December 2020 GST/HST Interpretation 209955- – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […] Unedited CRA Tags Public Service Body Rebate (GST/HST) Regulations- Section 2 Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. Excise and GST/HST Rulings Directorate Legislative Policy and Regulatory Affairs Branch 10-320 Queen Street, Tower A Ottawa, ON K1R 5A3 [Addressee] Case Number: 209955 [Dear Client] Subject: [GST/HST Interpretation] [Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […] We are writing in response to your [correspondence] of May 25, 2020, wherein you request that we rule on whether the […][Canada Emergency Wage Subsidy (“CEWS”)] and […][10% Temporary Wage Subsidy for Employers (“TWS”)] programs are considered government funding for purposes of the Public Service Bodies’ (“PSB”) Rebate. ... For additional information on the CEWS program, see the Canada.ca webpage frequently asked questions – Canada emergency wage subsidy (CEWS). 3. ...
Article Summary
Rob Kreklewetz & Stuart Clark, "Incoterms® 2020 Changes Incoming!", Millar Kreklewetz Tax & Trade Bog, 21 November 2019 -- summary under Paragraph 142(1)(a)
Rob Kreklewetz & Stuart Clark, "Incoterms® 2020 Changes Incoming! ... DAT becomes DPU – … Incoterms® 2020 now redefines DAT (Delivered at Terminal) as DPU (Delivered at Place Unloaded) … to reflect the fact that delivery could be at any place rather than just at a terminal. Security Requirements – Incoterms® 2020 also expands the terms related to obtaining security clearances for the shipment of goods. … ...
TCC
A & T Tire & Wheel Limited v. M.N.R., 2009 TCC 640
A & T Tire & Wheel Limited v. M.N.R., 2009 TCC 640 Docket: 2009-911(EI) BETWEEN: A & T TIRE & WHEEL LIMITED, Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and JUSTIN BUNN, Intervener.____________________________________________________________________ Appeal heard on common evidence with the appeal of A & T Tire & Wheel Limited (2009‑912(CPP)) on November 26 and 27, 2009 at Toronto, Ontario Before: The Honourable N. ... Weisman" Weisman D.J. Citation: 2009 TCC 640 Date: 20091224 Dockets: 2009-911(EI) 2009-912(CPP) BETWEEN: A & T TIRE & WHEEL LIMITED, Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent, and JUSTIN BUNN, Intervener. ... Weisman, Deputy Judge DATE OF JUDGMENT: December 24, 2009 APPEARANCES: Counsel for the Appellant: Leigh Somerville Taylor Counsel for the Respondent: Thang Trieu For the Intervener: The Intervener himself COUNSEL OF RECORD: For the Appellant: Name: Leigh Somerville Taylor Richler and Tari Toronto, Ontario For the Respondent: John H. ...
25 June 2015- 10:41am GMAC Leaseco – Tax Court of Canada finds that an amount received subject to future adjustment was unearned – but, by the same token, it was not “received” for s. 12(1)(x) purposes Email this Content GMAC received "support payments" from GMC in order to inflate the residual values stated in its leases of cars to GMC customers, thereby reducing the lease payments but resulting in a likely loss on lease termination. ... The Queen, 2015 TCC 146 under s. 9 – timing, s. 12(1)(x), s. 9 – compensation payments, s. 9 – computation of profit, s. 18(1)(a) – timing. ...
News of Note post
7 August 2017- 12:52am Halsall v Champion Consulting – High Court of England and Wales finds that knowledge that advice – that investing in a tax shelter was a “no brainer”- was negligent, commenced when HMRC started investigating Email this Content Investors in a UK charitable gift tax shelter subscribed for shares of a shell company and then, a short number of days later after the shell company had been listed on the AIM, donated their shares to a charity and claimed tax reductions on the basis that the shares had appreciated in value by four times. ... Summary of Halsall & Ors v Champion Consulting Ltd & Ors [2017] EWHC 1079 (QBD) under General Concepts – Negligence. ...
News of Note post
16 May 2017- 12:37am R & S Industries – Tax Court of Canada finds that a taxpayer is not bound by the statement of boot set out in its s. 97(2) election form Email this Content R & S Industries was unsuccessful in a motion to have the Federal Court direct CRA to reconsider its decision to not permit R & S Industries to file an amended s. 97(2) election form so as to change the agreed amounts. ... CRA viewed this as an attempted end-run around R & S’s inability to amend its election, and sought to have the appeal dismissed on jurisdictional grounds. ... Summary of R & S Industries Inc. v. The Queen, 2017 TCC 75 under s. 97(2). ...
9 March 2016- 11:39pm R & S Industries – Federal Court appears to interpret a s. 97(2) drop-down agreement as preventing a re-allocation of boot to avoid gain Email this Content An agreement for the drop-down under s. 97(2) of assets by the taxpayer (R & S) to a subsidiary LP specified that the elected amounts in a joint s. 97(2) election, and the respective portions of the Purchase Price allocated to the transferred assets, would be the minimum agreed amounts permitted under the Act, “provided …that in respect of the Goodwill, the elected amount shall, unless otherwise agreed be equal to $2,502,600.” ... When CRA rejected the request for an amended election, 15 months passed before R & S sought judicial review of this decision in the Federal Court. ... Summaries of R & S Industries Inc. v. MNR, 2016 FC 275 under Federal Court Act, s. 18.1(2) and ITA s. 97(2). ...
News of Note post
As well … procedural gaffes are not so egregious as to require or demand denial of this application. ... Russell J stated in this regard that “there is a semblance of logic to … [the corporation’s] position, sufficient to constitute reasonable grounds.” ... Bureau Barrister & Solicitor Incorporated v. The Queen, 2020 TCC 119 under ETA s. 305(5)(b). ...
News of Note post
28 February 2023- 12:08am K & D Logging – Tax Court of Canada finds that a s. 20(21) deduction cannot offset previously-recognized s. 17 income Email this Content The taxpayer (K & D) initially recognized interest from year to year at the prescribed rate under s. 17 on a loan to a Uruguay farming corporation (Interan) of which it was a 44% shareholder. ... K & D argued that it could obtain a deduction under s. 20(21), for the amount of the interest previously recognized by it, on the loan’s disposition (its partial repayment). ... Summary of K & D Logging Ltd. v. The King, 2023 TCC 23 under s. 20(21). ...