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Canada Pension Plan and Employment Insurance Explained – Information Technology Consultants – Employees or Self-Employed Workers?
For more information, see CPP/EI Explained – Employees and self-employed workers – Responsibilities, benefits, and entitlements. ... You can find more information in paragraphs 18 and 19 of Bulletin IT73 – The Small Business Deduction. ... For information on what the Canada Revenue Agency looks at when determining the employment status of placement/employment agency workers under the Canada Pension Plan and the Employment Insurance Act, see CPP/EI Explained – Placement/Employment Agencies. ...
10 October 2024 APFF Financial Strategies & Instruments Roundtable
Miscellaneous correspondence
Where the CCPC claims a foreign tax deduction under subsection 126(1) ("FTD"), a reduction is provided for in the description of B of the formula “A – B” in subparagraph (a)(i) of the definition of NERDTOH. More specifically, the reduction is equal to the amount by which the CCPC's deduction for the year under subsection 126(1) (the “FTD”) in respect of its foreign non-business income (clause (A) of element B of the “A – B” formula) exceeds 8% of the foreign investment income ("FII") (clause (B) of element B of the “A – B” formula). ... This notional calculation of 8% of FII in clause (B) of element B of the “A – B” formula applies regardless of whether a foreign country has levied a tax on foreign source income. ...
16 November 2016 Toronto Centre Canada Revenue Agency & Tax Professionals - International Tax Issues
Miscellaneous correspondence
Specifically, there were three things were identified in that Action plan: the master file, the local file, and – everybody’s favourite – the country-by-country reporting. ... There are other countries – the US in particular – that have not signed on to that. ... I think you’re right – the OECD and many others have said this is a risk-assessment tool – it is not a tool that will identify adjustments. ...
Preview of November 16, 2016 TCTSO CRA & Tax Professionals Group Seminar
Miscellaneous correspondence
Email this Content Preview of November 16, 2016 TCTSO CRA & Tax Professionals Group Seminar Preview of November 16, 2016 TCTSO CRA & Tax Professionals Group Seminar ...
20 November 2017 CTF Annual Conference - Diana Aird (Justice) on Rectification & Rescission
Miscellaneous correspondence
There is nobody from the CRA on the Committee – it is just a working group of lawyers. ... Contemporaneous documents are usually going to be the most persuasive evidence you have – they are much better than someone’s recollection of whatever the tax plan was, years after the fact. ... We sometimes encounter documents that are worded very vaguely – asking us to fix the tax mistake and allowing the taxpayer to draft whole new documents, “whatever is needed.” ...
26 February 2019 Toronto CRA & Tax Professionals - International Tax
Roundtable notes
BEPS Actions 8-10 (revised transfer pricing guidelines) The working party responsible for Actions 8-10 (“Working Party Six”) was the only BEPS party to operate on a consensus basis; that is, the soft language in those Actions was essentially by design – e.g. using “may” instead of “shall.” ... We have held off until now because the financial transactions project is not finalized – there may be some big changes coming out of that. ... We do not necessarily see that as the case – our penalty regime is based on reasonable efforts. ...
Commentary
Rectification & Rescission - Commentary
An attempt by the parties themselves to rectify their transactions on a nunc pro tunc basis may not be respected as having retroactive effect for tax purposes (see S & D), although the parties' self-help rectification in AES (replacing most of a promissory note with preferred shares) was effectively ratified after the fact in a Quebec context. ... However, in S & D, transactions were rectified so as to minimize adverse tax consequences to the extent consistent with the commercial intent of the parties, even though there had not been a continuing intention of the parties to avoid tax. ...
Conference summary
25 November 2012 Roundtable, 2013-0479401C6 F - Employés et Achat Ltée commentaires panel ARC -- summary under Paragraph 251(1)(c)
25 November 2012 Roundtable, 2013-0479401C6 F- Employés et Achat Ltée commentaires panel ARC-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) Buyco that is formed by employer to purchases departing employees’ shares is NAL In order to facilitate the disposition of shares of departing employees who had purchased their shares under an employee share ownership plan (ESOP), Opco forms and injects funds into a new company (Buyco), which uses those funds to purchase the employee’s Opco shares. ... This … is consistent with … 2007-0243171C6, 2002-0166655 and 2004-0103061E5 … Petro-Canada and … RMM …. ...
Decision summary
G E Financial Investments v.The Commissioners for Her Majesty's Revenue & Customs, [2021] UKFTT 0210 (Tax Chamber), ultimately aff'd [2024] EWCA Civ 797 -- summary under Article 4
G E Financial Investments v.The Commissioners for Her Majesty's Revenue & Customs, [2021] UKFTT 0210 (Tax Chamber), ultimately aff'd [2024] EWCA Civ 797-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 a deemed US resident was not a US treaty resident A US company (“GEFI Inc.”) and UK company (“GEFI”) in the GE group formed a Delaware LP (“LP”) with GEFI Inc. as the 1% general partner and GEFI as the 99% limited partner. ... In my judgment, this is the correct approach as it takes into account the common feature or similarity of domicile, residence, citizenship etc, in the context of the Convention, ie that they are all criteria providing, in addition to the imposition of a worldwide liability to tax, a “ connection ” or “ attachment ” of a person to the contracting state concerned. Such an interpretation is consistent with Widrig … and Vogel … and Crown Forest which, as [HMRC counsel] submits, when properly understood in context is authority for the proposition that full or worldwide taxation is a necessary feature of the connecting criterion but is not sufficient of itself. ...
FCA
Canada (Customs and Revenue Agency) v. Gl&V / Black Clawson-Kennedy Pulp and Paper Machine Group Inc., 2002 FCA 43
BETWEEN: THE COMMISSIONER FOR THE CANADA CUSTOMS AND REVENUE AGENCY FORMERLY KNOWN AS THE DEPUTY MINISTER OF NATIONAL REVENUE FOR CUSTOMS AND EXCISE Appellant and GL & V / BLACK CLAWSON-KENNEDY PULP AND PAPER MACHINE GROUP INC. ... Sébastien, the appeal will be dismissed with costs. ...