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Administrative Policy summary
26 August 2019 Comfort Letter - “Advantage”: Exclusion for Investment Management Fees -- summary under Subparagraph (b)(i)
26 August 2019 Comfort Letter- “Advantage”: Exclusion for Investment Management Fees-- summary under Subparagraph (b)(i) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (b)- Subparagraph (b)(i) where RRSP or TFSA fees (described in s. 20(1)(bb)) are paid by the annuitant or holder [If] investment management fees of registered plans … are paid directly by the holder/annuitant using funds outside of the plan, the resulting indirect increase in the value of the plan assets might be viewed as an advantage … if one of the main purposes is to benefit from the tax-exempt status of the plan. Even so, we have no tax policy concerns with respect to the payment of investment management fees directly by the annuitant/holder of the registered plan. … Generally, the direct payment of fees results in either a net loss, or negligible gain, for the plan holder. We are therefore prepared to recommend … clarifi[cation] that the payment by a controlling individual (as defined in subsection 207.01(1)) of investment management fees that pertain to a registered plan does not constitute an advantage … [and] [s]pecifically … that paragraph (b) of the definition "advantage" in subsection 207.01(1) be amended [respecting 2018 and subsequent taxation years] such that it does not apply to payments by a controlling individual of a registered plan, not exceeding a reasonable amount, of fees described in paragraph 20(l)(bb) …. ...
Administrative Policy summary
FAQ - Deferral of GST/HST Tax Remittances: CRA and COVID-19 20 April 2020 CRA Webpage (as amended on June 29, 2020) -- summary under Subsection 281.1(1)
This means that no interest will apply …. The deadline for businesses to file their returns is unchanged. … However … the CRA won’t impose penalties where a return is filed late provided that it is filed by June 30th. ... Q.4 No automatic deferral for excise duties Excise taxes and duties are still required to be remitted by their prescribed due dates. … Decisions to waive interest are made on a case by case basis. ... Q.9 No payment of housing/general rebate rebate claims Only the GST/HST rebate applications filed electronically for … Point-of-Sale and Public service bodies with the CRA can be processed automatically unless they require client contact or additional review. ...
Administrative Policy summary
23 March 2017 CBA Commodity Taxes Roundtable, Q.21 -- summary under Paragraph 254(2)(i)
CRA responded: [T]he formula outlined in paragraph 254(2)(i) … makes reference to the “total consideration” … described in paragraph 254(2)(c) … [as] the sum of the consideration payable for the housing itself (that is, the purchase price of $250,000) and the consideration payable for any other taxable supply of an interest in the housing (that is, the assignment fee of $150,000). ... A [instead] were not a builder, his assignment of the agreement of purchase and sale would be an exempt supply … and the consideration for the exempt assignment would not be included in determining the “total consideration” as described in paragraph 254(2)(c). … ...
Administrative Policy summary
28 February 2019 CBA Roundtable, Q.3 -- summary under Subsection 155(2)
See Taitz & Millar, ‘‘The GST and National Religious Organizations – Selected Issues”, GST & Commodity Tax (Carswell), Vol. V, No. 3, pp. 21-23 (April 1991), at p. 22., which states in respect of “Intercorporate Transactions” (in part): … [A]s an administrative concession, Revenue Canada stated that it would not apply the anti-avoidance rule in section 155 to any of the transactions between the various corporations, in order that the transactions could be completed for nil or nominal consideration. ...
Article Summary
Bradley Crawford, Crawford and Falconbridge Banking and Bills of Exchange, (Canada Law Book), 1987 -- summary under Borrowed Money
[fn no 2: The bank receives a fee from its customer (called an acceptance fee or "stamping fee" of about ¾ of 1% of the principal amount of the acceptance), as compensation for its services, but otherwise receives no value for the instrument, the proceeds of sale being paid directly to or to the order of the drawer.] ... [f.n. 6: "When one purchases a bearer deposit note or a bankers acceptance, one is in fact purchasing a chose in action – a debt owed by the bank. ...
Article Summary
Steve Suarez, "Canada's 88(1)(d) Tax Cost Bump: A Guide for Foreign Purchasers", Tax Notes International, December 9, 2013, p. 935 -- summary under Subparagraph 88(1)(c.3)(i)
. … These are important exceptions, since they allow, for example, the parent to issue shares or debt in exchange for money in order to finance an acquisition of the subsidiary, without having to worry about whether the persons acquiring the shares or debt are prohibited persons. ... Note, however, that this exception does not extend to stock options issued for other consideration — for example, options issued to subsidiary employees as an incentive to remain with the company post-AOC [acquisition of control].] ...
Article Summary
Bruce Sinclair, "Current Topics in the Taxation of Real Estate Development", 2014 Conference Report, (Canadian Tax Foundation), 12:1-24. -- summary under Subsection 160(1)
It is clear that the payment of a stock dividend does not constitute a transfer of property…[a]s… stated in Algoa Trust …. ... " [fn 22: … 98 DTC 6358, at paragraph 20…] Applying such a broad interpretation, a court could find that property of Projectco has been transferred indirectly to the developer. ...
Article Summary
J. Harold McClure, "Evaluating Whether a Distribution Affiliate Pays Arm's-Length Prices for Mining Products", Journal of International Taxation, July 2014, p. 33. -- summary under Subsection 247(2)
DuPont de Nemours & Co., 608 F.2d 445 (Ct. CL, 1979), was an influential transfer pricing case. ... Glencore also recently entered into an off-take agreement with Sirius Petroleum….Off-take agreements are widely used in the mining and oil sectors. … In other situations, they are between independent parties. ...
Article Summary
Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Beneficiaries Resident in Canada", Chapter 4 of Canadian Taxation of Trusts (Canadian Tax Foundation), 2016. -- summary under Subsection 107(2)
[fn 42: 2014-0538261C6] … The CRA's conclusions in this technical interpretation may represent an overly narrow reading of subsection 107(2). ... [T]he only question at issue was presumably whether the trustees had, as a matter of trust law, the power to distribute property to the beneficiaries of the trust in their capacity as partners of the partnership. … There appears to have been a very compelling position that subsection 107(2) should apply to a direct distribution of trust property to the partnership on the basis that the partnership should be regarded as a beneficiary under the trust, even without a variation of the terms of the trust. ...
Article Summary
Eytan Dishy, Chris Anderson, "The Permissibility of Surplus Stripping: A Brief History and Recent Developments", Canadian Tax Journal (2021) 69:1, 1 -33 -- summary under Subsection 245(4)
Fourth, the courts have generally refrained from applying GAAR to surplus-stripping transactions involving arm’s-length transfers – see McMullen (the taxpayer and his business associate, who had different interests in the severing of their business relationship and were dealing at arm’s length, and whose transactions were each found to be undertaken for bona fide non-tax purposes of separating the business), and Univar (finding that the series of transactions stemmed flowed from an arm’s-length purchase of shares, a context in which s. 212.1 did not apply. ... In Example 3, per “ Geransky and Kennedy, the sale of the capital assets in and of itself should not constitute a reorganization for the purposes of subsection 84(2) provided that R Co continues to carry on the same business.” ...