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Kevin Wark, Michael O'Connor, "The Next Phase of Life Insurance Policyholder Taxation is Nigh", Canadian Tax Journal (2016) 64:4, 705 - 50-- summary under Paragraph 306(6)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 306- Subsection 306(6)- Paragraph 306(6)(b) Redating of exempt test policy where >250% increase in accumulating fund over 3 years (p. 721) In addition to the so-called 8 percent test, another rule currently applies to limit the size of deposits made to the policy after the policy has been in force for 10 years or longer. ...

Alan Kenigsberg, "Changes to Tax Treatment of ILPs under the ETA", Sales Tax, Customs & Trade, Volume XV, No 2, Federated Press, 2018, p.9-- summary under Investment Limited Partnership Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Investment Limited Partnership Purpose of ILP rules (p. 9) We understand that the new measures were aimed at preventing certain investment funds from structuring their affairs as a limited partnership that pays the manager of the fund (acting as the general partner of the limited partnership) an exempt partnership distribution rather than a taxable payment for management and administrative services. ...

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Paragraph. 95(2)(z) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph. 95(2)(z) Example of curative effect of s. 95(2)(z) (pp. 20:63-64) In this example, Inactive FA earns interest income from Active FA. ...

Joint Committtee, "Federal Budget 2024 – Capital Gains Inclusion Rate", 22 January 2025 Joint Committee submission-- summary under Paragraph 38(a) Summary Under Tax Topics- Income Tax Act- Section 38- Paragraph 38(a) While the proposals to generally increase the capital gains inclusion rate (the “Capital Gains Proposals”) were not tabled in Parliament in the form of a bill before Parliament was prorogued on January 6, 2025 and there is substantial possibility that they will never be enacted, the Department of Finance and the CRA have confirmed that the ITA will be administered as though they were enacted. ...

Grant Russell, Philippe Montillaud, "'Fresh Start' Rules – on Becoming an Affiliate",, International Tax Planning (Federated Press), Vol. ...

John Lorito, Trevor O'Brien, "International Finance – Cash Pooling Arrangements", 2014 Conference Report, (Canadian Tax Foundation), 20:1-33-- 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) Difficulties in establishing tracing in cash pool (p. 22) It may be possible for interest earned by a foreign affiliate from deposits/loans made under a cash pooling arrangement to be re-characterized to be income from an active business under subparagraph 95(2)(a)(ii) where the head account holder is another foreign affiliate, however, many complexities exist. ...

Xiao, "The 88(1)(d) Bump – An Update", 2013 Conference Report (Canadian Tax Foundation), pp.13:1-60-- summary under Paragraph 88(4)(b) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(4)- Paragraph 88(4)(b) Is debt of Target non-specified property after it is amalgamated with Bidco? ...

Durst, "The OECD Discussion Draft on Safe Harbors – And Next Steps", Viewpoints, Tax Notes International, 13 August 2012, p. 647-- summary under Article 9 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 9 Respecting the discussion draft of the OECD's Working Party 6 recommending that the OECD adopt changes to its transfer pricing guidelines to envision that tax administrations develop safe harbour ranges of arm's-length margins and markups for use in benchmarking the incomes of relatively uncomplicated business operations conducted by members of multinational groups, Durst states (p. 647): The discussion draft, in my view, responds in a sensible manner to some of the most common and serious practical difficulties that have arisen in transfer pricing practice over the past several decades. ...

Timothy Hughes, Matias Milet, Marc Richardson-Arnould, "Private Equity Funds – Selected Canadian Tax Issues", Tax Management International Journal, 2016, p.84-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Advantages of separate fund for Canadian investors (p. 87) A non-Canadian private equity fund that expects to have significant investor capital sourced in Canada and to invest in Canadian portfolio companies should consider forming a separate fund restricted to Canadian investors that would invest in parallel with the main fund….In addition to permitting certain tax-deferred entry and exit transactions for Canadian investors, a parallel fund avoids two significant indirect tax inefficiencies associated with investing in a partnership that has one or more non-Canadian members (a "Non-Canadian Fund"):… Avoidance of s. 116 withholding (p. 88) [I]f the Non-Canadian Fund Sells property (e.g. shares in the capital stock of a Canadian portfolio company) that are TCP, this can result in the TCP rules being indirectly visited upon Canadian investors. ...

Turner, "Transitional Tax Treatment of Grandfathered Upstream Loans – Repayment Deadline Approaching", International Tax (Wolters Kluwer CCH), No. 88, June 2016, p. 7-- summary under Subsection 90(9) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(9) Perennial reserve and inclusion mechanism (p. 6) When the Canadian taxpayer (or the "specified debtor") finally repays the upstream loan or indebtedness (but not as part of a series of loans and repayments), the repayment amount may be deducted from income under subsection 90(14). ...