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Chris Lang, "Debt Restructuring Using a Reverse Vesting Order: Tax Issues", Canadian Tax Focus, Vol.15, No. 2, May 2025, p. 2 -- summary under Subsection 80(13)
Chris Lang, "Debt Restructuring Using a Reverse Vesting Order: Tax Issues", Canadian Tax Focus, Vol.15, No. 2, May 2025, p. 2-- summary under Subsection 80(13) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(13) Overview of Delta 9 (p. 2) In Delta 9, a licensed producer of cannabis (the target corporation) had entered CCAA proceedings. ... Peakhill Capital Inc. (2024 BCCA 246) …. ...
Article Summary
Marissa Halil, David Carolin, Manu Kakka, "Are Section 84.1 Intergenerational Transfers (Mission) Impossible? The Meaning of “De Facto Control” in the Context of Subsection 84.1(2.31)", Tax for the Owner-Manager, Vol. 25, No. 1, January 2025, p. 1 -- summary under Paragraph 84.1(2.31)(c)
The Meaning of “De Facto Control” in the Context of Subsection 84.1(2.31)", Tax for the Owner-Manager, Vol. 25, No. 1, January 2025, p. 1-- summary under Paragraph 84.1(2.31)(c) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2.31)- Paragraph 84.1(2.31)(c) Accommodation of 3-year retention of management while requirement to immediately relinquish de facto control (p.1) The immediate intergenerational transfer rules in s. 84.1(2.31) contemplate that the parents must (inter alia) give up de facto control of the business immediately after the disposition time, while being allowed to retain “management” of the business for up to three years after the disposition time. ... Langlois, which found that a 50% shareholder who had “an operational role, not a decision-making role” was not part of the de facto control of the corporation, whereas the other shareholder, who “[a]s the sole director … had the power that ensured him a dominant influence in the direction of the [corporation]” had de facto control. ...
Article Summary
Mark Jadd, Daniel Safi, "When a Non-Resident Might Qualify as a “Parent” Under the FAD Rules: A Potential for Retroactive Application?", International Tax Highlights, Vol. 4, No. 1, February 2025, p. 4 -- summary under Paragraph 212.3(1)(b)
", International Tax Highlights, Vol. 4, No. 1, February 2025, p. 4-- summary under Paragraph 212.3(1)(b) Summary Under Tax Topics- Income Tax Act- Section 212.3- Subsection 212.3(1)- Paragraph 212.3(1)(b) Scenario (p. 4) A widely-held private corporation resident in Canada (the “CRIC”) will emigrate from Canada for non-tax reasons. ... However, under s.212.3(1)(b), the s. 212.3 rules apply to an investment made by the CRIC in a subject corporation if as part of the series of transactions that includes the making of the investment, Forco acquired control of the CRIC and at the time of the “investment”, the Forco shares represented 25% or more of the votes or value of the CRIC – with s. 251(5)(b) rights being taken into account for these purposes. ...
Article Summary
Joint Committee, "Section 116 of the Income Tax Act", 24 January 2025 Joint Committee submission to the Assistant Commissioner of the Compliance Programs Branch of CRA -- summary under Subsection 116(5)
Joint Committee, "Section 116 of the Income Tax Act", 24 January 2025 Joint Committee submission to the Assistant Commissioner of the Compliance Programs Branch of CRA-- summary under Subsection 116(5) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(5) Recommendations on the administration of s. 116 include: That CRA develop a system automatically generating a comfort letter (for extending the 30-day remittance deadline until the processing of the application). ... That, where CRA has determined that the subject property is not TCP, it issue a s. 116 certificate on that basis, rather than a letter stating that it cannot issue a certificate because the property is not TCP (the certificate could be issued on the basis that no Canadian income tax is owing on the disposition) – or, failing that, publish a position that such a “No-TCP” letter releases the purchaser from liability. ...
Administrative Policy summary
CRA Webpage, Enhanced reporting rules for trusts and bare trusts: Frequently asked questions, updated on 14 March 2025 -- summary under Subsection 162(7)
CRA Webpage, Enhanced reporting rules for trusts and bare trusts: Frequently asked questions, updated on 14 March 2025-- summary under Subsection 162(7) Summary Under Tax Topics- Income Tax Act- Section 162- Subsection 162(7) no s. 162(7) penalty for 2023 taxation year of bare trust unless gross negligence 3.5. ... … As some bare trusts may be uncertain about the new requirements, the CRA is adopting an education-first approach to compliance and providing relief to bare trusts by waiving the penalty payable under subsection 162(7) of the Income Tax Act for the 2023 tax year in situations where the T3 Return and Schedule 15 are filed after the filing deadline for reasons other than gross negligence. … This proactive relief is for bare trusts only and only for the 2023 tax year. ...
Administrative Policy summary
GST/HST Memorandum 14-9-1 “Partnerships - Determining the Existence of a Partnership” March 2025 -- summary under Section 96
GST/HST Memorandum 14-9-1 “Partnerships- Determining the Existence of a Partnership” March 2025-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 Relevance of ITA treatment 15. … [W]hen a partnership is recognized for income tax purposes, it will be treated as one for GST/HST purposes, and so the income tax considerations are relevant for GST/HST purposes as well. ... Determination of partnership status of foreign partnership by reference to provincial law 20. … Continental Bank … Backman … and Spire Freezers confirmed that the existence of a partnership must be determined by reference to the relevant partnership law of the province or territory and this is the case even when dealing with a partnership established in a jurisdiction outside Canada. ... In addition, express declarations against the existence of a partnership will not be determinative if the facts indicate otherwise. … 31. ...
Administrative Policy summary
CRA Webpage, Enhanced reporting rules for trusts and bare trusts: Frequently asked questions, updated on 14 March 2025 -- summary under Subsection 163(5)
CRA Webpage, Enhanced reporting rules for trusts and bare trusts: Frequently asked questions, updated on 14 March 2025-- summary under Subsection 163(5) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(5) s. 163(5) gross negligence penalty could be imposed for failure to file a return 1.10 … Errors or omissions may be identified by the CRA based on a review of the information filed. If the trust is not a listed trust and a person knowingly or under circumstances amounting to gross negligence makes, — or participates in, assents to or acquiesces in, the making of — a false statement or omission on a return required to be filed, or fails to file a return, a penalty may apply under subsection 163(5). ...
Administrative Policy summary
Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025 -- summary under Paragraph 214(3)(a)
Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025-- summary under Paragraph 214(3)(a) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(3)- Paragraph 214(3)(a) Deferred imposition of Part XIII tax 1.90 … If there is no series of loans or other transactions and repayments, the non-resident who has received a loan in a particular taxation year cannot be deemed to have received a dividend until one year after the end of the lender's tax year. ... If the tax is not remitted by this day, interest will start accruing as of the 16th day of the month following the end of the lender's tax year. 1.92 If a PLOI election is available in respect of a loan but has not yet been filed, the CRA will assess Part XIII withholding tax after the time period described in subsection 15(2.6) has elapsed. … Assignment of loan before repayment 1.97 In a situation where a loan amount that is owed by a non-resident borrower has been assigned by the original lender to a new lender and the borrower subsequently repays the loan to the new lender, the borrower may still be entitled to a refund of the Part XIII tax previously assessed. ...
Administrative Policy summary
CRA Webpage, Enhanced reporting rules for trusts and bare trusts: Frequently asked questions, updated on 14 March 2025 -- summary under Subsection 104(1)
CRA Webpage, Enhanced reporting rules for trusts and bare trusts: Frequently asked questions, updated on 14 March 2025-- summary under Subsection 104(1) Summary Under Tax Topics- Income Tax Act- Section 104- Subsection 104(1) Meaning of trust 1.1. ... … Separation of legal and beneficial ownership Ordinarily, a person who has legal title to a property also has the ability to use, enjoy and “benefit from” the property. ... The beneficiaries have rights against the trustees to enforce the terms of the trust. … Trust vs. agency and bare trusts Trust relationships are distinct from agency relationships, even though both trustees and agents act on behalf of other persons. ...
Administrative Policy summary
Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025 -- summary under Subsection 15(2.17)
Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025-- summary under Subsection 15(2.17) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.17) Overview 1.18 … In very general terms, where the conditions set out in subsection 15(2.16) are met, subsection 15(2.17) deems that the particular corporation or partnership made a loan to the borrower for the purposes of sections 15 and 80.4, in an amount equal to the funding indirectly provided. ...