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Duff, "Tax Treaty Abuse and the Principal Purpose Test – Part 2", Canadian Tax Journal, (2018) 66:4, 947-1011-- summary under Article 6(1) Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 6- Article 6(1) Preamble effectively overrides Union of India approach (p. 891) [I]t is necessary to consider not only the primary arm of the CTA to encourage cross-border economic activity by allocating taxing rights in a fair and reasonable manner in order to reduce or eliminate double taxation, but also the intention of the contracting jurisdictions that the CTA not create opportunities for non-taxation or reduced taxation through tax treaty shopping and other forms of tax avoidance. ...

Duff, "Tax Treaty Abuse and the Principal Purpose Test – Part 2", Canadian Tax Journal, (2018) 66:4, 947-1011-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) Burden on Crown to establish abused policy (p. 1001) Canadian courts have generally held that the GAAR should apply only where the object and purpose of the relevant provisions is "clear and unambiguous”. ...

PWC, "GST/HST and QST alert: Investment plans are required to obtain investor percentages – action required by October 15, 2019", PwC Tax Insights, September 03, 2019, Issue 2019-31-- summary under Subsection 52(10) Summary Under Tax Topics- Excise Tax Act- Regulations- Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations- Section 52- Subsection 52(10) overview/qualified investors should be contacted Qualifying investors A qualifying investor is generally an investor that is an investment plan (but not a DIP) that holds less than $10,000,000 in units in the DIP (or, if the plan is a stratified investment plan, holds less than $10,000,000 in units in a series of the plan) and is: a person that is not a qualifying small investment plan (QSIP) or a pension plan whose members reside almost exclusively in non-HST provinces for GST/HST purposes (or exclusively outside Quebec for QST purposes) or a private investment plan a SLFI, or a member of an affiliated group, the members of which together hold units with a total value of at least $10,000,000 or which includes a member that is a SLFI Written requests are not required to be sent to qualifying investors. ...

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Paragraph 5907(11.2)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(11.2)- Paragraph 5907(11.2)(b) LLCs can generate exempt earnings (pp. 20:10-11) [T]he fundamental requirement—established in paragraph (d) of the “exempt earnings” definition in regulation 5907(1)—is that the FA be resident in a designated treaty country (DTC)…. ...

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Subclause 95(2)(a)(ii)(B)(II) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(B)- Subclause 95(2)(a)(ii)(B)(II) Dubious textual interpretation of s. 95(2)(a)(ii)(B)(II) (“Cap B”) in 2016-0680801I7 (pp. 20:65-69) The CRA recently considered the application of Cap B in recharacterizing interest income earned by an inactive FA that has made a loan to a partnership that was not wholly owned by the CRIC’s group. ...

Jim Samuel, Byron Beswick, "Selected Issues in Transactions Involving Debt", 2019 Conference Report (Canadian Tax Foundation), 18:1 – 27-- summary under Paragraph 20(14)(a) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(14)- Paragraph 20(14)(a) Apply s. 52(1) basis increase to avoid double-taxation of s. 20(14)(a) income inclusion (p. 18:14) If an amount is included in computing a transferor’s income under paragraph 20(14)(a), no provision in the Act explicitly excludes that amount in the computation of the transferor’s gain or loss otherwise determined in respect of the disposition of the debt. ...

Raj Juneja, Pierre Bourgeois, "International Tax Issues That Get in the Way of Doing Business", 2019 Conference Report (Canadian Tax Foundation), 36:1 – 42-- summary under Specified Right Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(5)- Specified Right Uncertainty regarding specified right exclusion in multiparty group secured facility Under a multiparty credit agreement, all parties (Foreign Parent, Canadian Subsidiary and Foreign Subsidiary) guarantee the borrowed sums and pledge their assets except that for foreign tax reasons neither subsidiary guarantees debt of Foreign Parent. ...

Tim Barrett, Andrew Morreale, "Foreign Affiliate Update", 2019 Conference Report (Canadian Tax Foundation), 35: 1 – 53-- summary under Paragraph 15(1.5)(a) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1.5)- Paragraph 15(1.5)(a) Share cancellation requirement The s. 15(1.5)(a) demerger rule does not apply where the shares of the demerging corporation are cancelled, which may be required under the corporate law in some jurisdictions. ...

PWC, "Tax Insights: The underused housing tax – A new compliance requirement for many owners of Canadian residential property", Issue 2023-06R, 5 April 2023-- summary under Residential Property Summary Under Tax Topics- Other Legislation/Constitution- Federal- Underused Housing Tax Act- Section 2- Residential Property a building or condo unit is not a residential property until it is substantially completed The GST/HST Rulings Directorate issued a technical interpretation to the Canadian Home Builders Association on March 10, 2023 indicating: a property becomes “residential property” for UHT purposes when its construction is substantially completed (generally, 90% or more), so that it could be reasonably inhabited a builder/owner is not required to file a UHT return for a calendar year in respect of a property if its construction was not substantially completed on December 31 of the year a condominium complex does not have to be registered as such for its units to be regarded as “residential property” for UHT purposes, but an individual unit does have to be substantially completed by December 31 to require the builder/owner to file a UHT return in respect of the unit for that year a property’s assessed value and most recent sale price do not have to be reported on a UHT return (“$0” can be entered on lines 280 and 285) if: (i) no tax is payable in respect of the property, due to an available exemption; and (ii) the UHT return is filed by December 31 of the following calendar year ...

Hybrid Financing – A Canadian Perspective on the U.S. Debt-Equity Regs", 26 September 2016, p. 1151-- summary under Clause 95(2)(a)(ii)(B) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(B) Recharacterization rules under Code s. 385 (p.1152) Most fundamentally, the proposed regulations would automatically treat what would otherwise be classified as a debt instrument as equity when a debt instrument is part of some distributions or related-party transactions. ... (p. 1158) [T]here is a new advance of money being invested in the U.S. operations — the debt from the Luxembourg SARL to U.S. ...