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Article Summary
Ian Gamble, "Income from a Business or Property: General Principles and Current Issues", 2014 Conference Report, Canadian Tax Foundation, 5:1-32 -- summary under Contracts
[fn 110: … Bache, 2011 FCA 104, at… 22 and 41.]… Break fees as capital receipts (p. 5:25) [E]arlier decisions made in the context of option agreements are helpful and persuasive. ...
Article Summary
Eric Lockwood, Maria Lopes, "Subsection 88(3): Deferring Gains on Liquidation and Dissolution", Canadian Tax Journal (2013) 61:1, 209-28, p. 209 -- summary under Subsection 93(1)
Eric Lockwood, Maria Lopes, "Subsection 88(3): Deferring Gains on Liquidation and Dissolution", Canadian Tax Journal (2013) 61:1, 209-28, p. 209-- summary under Subsection 93(1) Summary Under Tax Topics- Income Tax Act- Section 93- Subsection 93(1) They provide various examples indicating that a taxpayer (Canco) will realize a capital gain on the disposition of its shares of the disposing affiliate (Foreignco 1) – even where there has been a qualifying liquidation and dissolution (QLAD) election- where the adjusted cost base of Foreignco 1 in the distributed property, being the shares of Foreignco 2 (i.e., the inside basis), exceeds Canco's ACB of its Foreignco 1 shares, i.e., the outside basis. ...
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Matthew Warren, Eileen Scott, Alan Fischl, Sergio Lugo Dimas, "U.S. Foreign Tax Credibility of the Mexican Cash Deposits Tax", Journal of International Taxation, October 2013, p. 37 -- summary under Non-Business-Income Tax
Commissioner ", Tax Management International Journal, October 8, 1993, p. 539: Discussion of Brazilian interest withholding tax of 25% in respect of which borrowers taking out loans duly registered with the Brazilian Central Bank could receive a pecuniary benefit equal to 85% of the tax paid on the interest. ...
Article Summary
Carla Hanneman, "Reorganization Strategies for Proposed Paragraph 55(3)(a)", Canadian Tax Focus, Volume 5, Number 3, August 2015, p.8. -- summary under Paragraph 55(3)(a)
Alternative using butterfly-style mechanics (p. 9) Some practitioners might consider another way of implementing the transfer, which differs in steps 3 through 6: … 3) Holdco transfers shares of Opco (with a value equal to the value of the OPco assets transferred to Newco in step 2) to Newco in exchange for shares of Newco on a tax-deferred basis. 4) Newco redeems the shares that it issued to Opco in step 2 and issues a note to Opco as an in-kind redemption payment for the redeemed shares. 5) Opco redeems the shares that Newco received in step 3, and issues a note to Newco as an in-kind redemption payment for the redeemed shares. 6) The notes issued in steps 3 and 4 are offset and cancelled. ...
Article Summary
Angelo Nikolakakis, Alain Léonard, "The Acquisition of Canadian Corporations by Non-Residents: Canadian Income Tax Considerations Affecting Acquisition Strategies and Structure, Financing Issues, and Repatriation of Profits", 2005 Conference Report, c. 21, p. 21:8. -- summary under Subsection 212.1(4)
Section 212.1 does not apply because this is not a transfer of the shares of one corporation resident in Canada to another, and there is no gain from the disposition of the Target shares because they were just acquired in a taxable arm's-length transaction. 30 In step 2, Bidder transfers Bidder Forco shares and the Bidder Forco reorganization note to Bidder Canco in | exchange for Bidder Canco shares and a promissory note ("the Bidder Canco capital note") in an appropriate combination. ...
Article Summary
Joyce A. Young, H. Michael Dolson, "Income Tax Consequences of Carrying on an Unrelated Business", Business Vehicles, Volume XV, No. 1, 2012, p. 782, at 783, 784-785 -- summary under Subsection 188.1(1)
.] … There appears to be some consensus between the Minister and the academic commentators that the carrying on of a business by a trust established for the benefit of a charity does not constitute a business of the charity.… The better view of the law is that the business carried on by a trust is a business of the trustees and not a business of the trust beneficiaries. ...
Article Summary
Marie-Eve Gosselin, Paul Lynch, "A Review of Interest Deductibility Since Ludco", 2015 CTF Annual Conference paper -- summary under Paragraph 20(1)(c)
. … CRA challenges to intercompany interest charges (p.7:18) We have seen challenges [to the reasonableness of the interest rate] in related groups, between sister companies, parents and subsidiaries, and cross border hybrid debt structures. ...
Article Summary
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper -- summary under Subsection 80(13)
. … [C]areful tax modeling will be required to ensure that no material cash taxes will arise in the year of the restructuring as a result of the income inclusion under subsection 80(13), taking into account the potential five-year inclusion under section 61.4…. ...
Article Summary
Ian Bradley, Denny Kwan, Dian Wang, "Is The Back-to-Back Withholding Tax Regime an Effective Anti-Treaty-shopping Measure?", Canadian Tax Journal, (2016) 64:4, 833-58 -- summary under Subsection 212(3.2)
The deemed interest will be $20, because it is adjusted to reflect the difference in withholding tax rates between payments to NR 1 and NR 3, as a proportion of the rate on payments to NR 1 (that is, [15% — 10%]/15%). ...
Article Summary
Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Trusts Resident in Canada", Chapter 3 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016. -- summary under Paragraph 251.1(4)(d)
[fn 54: 2009-0308611R3 ….] This interpretation may not be correct as a matter of trust law. ...