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Article Summary
Manal Corwin, Jesse Eggert, "Understanding the Operation, Impact, and Practical Implications of the MLI", Tax Management International Journal, Vol. 46, No. 8, 11 August 2017, p. 407 -- summary under Article 28(2)
[f.n. 126: … art, 28(2)(a).] Such "free form" reservations are subject to objection by other parties, and if a party objects, Part VI will not apply at all between the reserving party and the objecting party. ...
Article Summary
Hugh Chasmar, "Corporate Class Funds", Canadian Tax Highlights, Vol. 25, No. 8, August 2017, p. 6 -- summary under Qualifying Exchange
. … In TI 9608465, the CRA concluded that in a proposed merger of two trusts (the one trust being the “top fund” and the other being the “bottom fund” of a fund-of-fund structure), the top fund could not transfer units of the bottom fund to that fund: the proposed merger was not a qualifying exchange. ...
Article Summary
Doron Barkai, Alexander Demner, "Dealing with New Subsection 55(2): Issues and Strategies", 2016 Conference Report (Canadian Tax Foundation), 6:1–56 -- summary under Paragraph 55(2.3)(a)
However, unlike paragraph 55(5)(f) …, subsection 55(2.3) does not explicitly split the dividend into two separate dividends. ...
Article Summary
Alex Klyguine, "Income Splitting After the New Private Corporation Proposals: Salaries Paid to Family Members", Canadian Tax Focus (Canadian Tax Foundation), Vol. 8, No. 1, February 2018, p. 1 -- summary under Section 67
Gabco test (p. 1) In Gabco … [t]he court established a frequently quoted (most notably, in Transalta Corporation v. ...
Article Summary
Joint Committee, "Reporting Requirements in Respect of Foreign Affiliates", 18 May 2018 Joint Committee Submission re accelerated T1134 filings -- summary under Subsection 233.4(4)
IV of the T1134 form contemplates that unavailable information will not be provided until later, CRA may now receive far more incomplete returns, and refiling returns will be inefficient both for taxpayers and CRA If there is an accelerated filing deadline, 12 months would be more appropriate so as to align with the filing deadline for country-by-country reporting – but even this would be problematic for jurisdictions such as the U.K. and Germany where tax returns are allowed to be filed 12 months after year end. ...
Article Summary
Joint Committee, "Definition of 'Public Corporation'", 4 March 2019 Joint Committee Submission -- summary under Paragraph (a)
(a) of the definition of public corporation – that a listed Canadian corporation is a public corporation- be amended by adding a proviso that this will not be the case where the corporation ceased to be a public corporation under para. ...
Article Summary
Daniel Sandler, Lisa Watzinger, "Disputing Denied Downward Transfer-Pricing Adjustments", Canadian Tax Journal, (2019) 67:2, 281-308 -- summary under Subsection 247(10); Subsection 247(10)
In practice … we have found that CRA Appeals takes the position that the Appeals Branch has no authority to review a denied downward adjustment, and considers a notice of objection in which a denied downward adjustment is the only issue in dispute to be invalid. ...
Article Summary
Jeffrey T. Love, Kenneth R. Hauser, "How Various Aggregation Rules Apply to Trusts", 2018 Conference Report (Canadian Tax Foundation), 28: 1-79 -- summary under Subparagraph 248(25)(b)(ii)
. … Subparagraph 248(25)(b)(ii) contemplates that a person or partnership exercises discretion to make the other person or partnership beneficially interested in the particular trust, under either the terms or conditions of the particular trust or an arrangement in respect of a particular trust. ...
Article Summary
Jeffrey T. Love, Kenneth R. Hauser, "How Various Aggregation Rules Apply to Trusts", 2018 Conference Report (Canadian Tax Foundation), 28: 1-79 -- summary under Subsection 248(25)
Also … Lyrtech RD…held that subsection 248(25) did not apply to paragraph 251(5)(b). ...
Article Summary
Jeffrey T. Love, Kenneth R. Hauser, "How Various Aggregation Rules Apply to Trusts", 2018 Conference Report (Canadian Tax Foundation), 28: 1-79 -- summary under Paragraph 256(1.2)(f)
. … When subparagraph 256(1.2)(f)(ii), (iii), or (iv) applies to deem a person to own shares owned (or deemed to be owned) by the trust, two uncertainties arise. ...