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In 1954 the words ‘‘on behalf of '' were added. This phrase was changed to ‘‘in the name of '' — the literal wording of the French version — in 1958 for no discernible reason.... ... Katharina Daxkobler of the Vienna University of Economics and Business mused that the French version— which contained the mischievous words ‘‘in the name of '' — might have been re-translated too literally because article 5(5) really asks whether the agent can bind the principal. ... Dell – commissionaire did not act for principal (p. 14) In Dell Products (NUF) v. ...

To illustrate … [A]ssume that the taxpayer’s share of the LLC income is $15,000 in respect of which the taxpayer paid U.S. tax of $4,500. ... The amount that may be deducted under subsection 20(11) of the Act is: $4,500 − (15% × $10,000) = $4,500 − $1,500 = $3,000. [fn: 121 … 1999-0010305] … [I]f the LLC distributed only $3,000 to the individual member in the year, then only a subsection 20(11) deduction would be available in respect of the $4,500 US non-business-income tax paid by the individual member. … ...

Investco has an investment portfolio worth $2 million and earns $90,000 in investment income annually … [which] should be fully included in Investco's AAII. … SBD limit reduction = SBD limit of $500,000/$500,000 × 5 × (AAII of $90,000 − $50,000) = $200,000 Thus, Opco will have an SBD limit of $300,000 …. ... X could hold the same portfolio in a partnership (Invest LP) … through holding companies (Holdco X and Holdco Y, respectively) [T]he AAII of Holdco X is $45,900 ($90,000 × 51%) …. ... Potential for spousal Holdcos to be associated under s. 256(2.1) (p.5) Consideration should be given to … subsection 256(2.1) …. ...

[f.n. 35 … 1999-0014275 … and … 2002-0128435 …]. A purported FTS which is ultimately determined to be a prescribed share is not, however, subject to subsection 63.3(3) and instead has full cost base. [f.n. 36 … 2000-0062937 …]. ...

Kandev, "Foreign Affiliate Issues in Troubled Times", International Tax (Wolters Kluwer CCH), No. 112, June 2020, p. 1-- summary under Paragraph 95(2)(g.1) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(g.1) S. 95(2)(g.1) applies on the basis of whether interest would be deductible from FAPI (pp. 2-3) 2002-0165195 … (the "2002 Technical") … [considering] that the forgiveness of a debt made by Canco to CFA1, the proceeds of which were used by CFA1 to acquire shares of CFA2 would not give rise to the application of the debt forgiveness rules because the debt was used to earn dividends from an FA and that such dividends are not to be included in the FAPI …. was overridden … in … 2004-0062175 … (the "2004 Technical") …. ... Potential application of s. 248(27) where dual-use debt (p. 3) [R]espect[ing] debt partly used for the purposes of earning FAPI and partly used for the purposes of earning active business income … the 2002 Technical … took the position that the whole amount of such debt would constitute a "commercial debt obligation" …. ...

The Queen …, [fn 5: Sub nom water's Edge Village Estates (Phase II) Ltd., … 2002 FCA 291 ….] the Tax Court in Triad Gestco Ltd. v. The Queen…, [fn 6: … 2011 TCC 259 …aff'd … 2012 FCA 258 …] and, in the context of a provincial general anti-avoidance rule, the Court of Québec in Ogt Holdings Ltd. c. ... The Queen … [fn 25: … 2008 TCC 274, para. 121; aff'd … 2009 FCA 113.] and 1207192 Ontario Ltd. v. ...

The CRA’s position is that the deemed year-end in subsection 249(3.1) does not occur when a corporation undergoes a change in status if the corporation has made a subsection 89(11) election in the same taxation year [fn 50: … 2010-0377251E5 … 2014-055019117 … and … 2014-0523171E5] because subsection 89(11) applies from the beginning of the year in which the change in status occurs. ...

Application of the requirement – that the proceeds be received by the grantor of the non-compete covenant or an eligible corporation thereof – to a trust or partnership (pp.12-13) [Under s. 56.4(7)(b)] generally, consideration must be received by either the "taxpayer" or an "eligible corporation" of the taxpayer. ... The reference to " the amount" rather than " an amount" suggests that it may be necessary to allocate to each partner that portion of the goodwill amount that directly represents consideration for the Non-Competition Covenant granted by that party…. ...

Morphy, "The Modern Approach to Statutory Interpretation, Applied to the Section 15 Anomaly in Foreign Affiliate Financing", Canadian Tax Journal, (2013) 61:2, 367-85:-- summary under Subsection 15(2.3) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.3) Example 1 – loan to direct foreign sub (pp. 369-370) In example 1, a Canadian parent ("Canco") makes an interest-free loan ("the loan") to a wholly owned foreign subsidiary ("Forco"), which uses the loan for the purpose of earning income from an active business. ... Example 2 – loan to foreign holding company for Opco (pp. 370-371) Should the result change for the arrangement depicted in example 2, where Forco holds all of the shares of another active or inactive foreign subsidiary ("Subco") but still carries on an active business in respect of which the loan proceeds are used? ...

This conflict undermines the duty of commitment to the client’s cause, a duty found … in the Federation’s [money-laundering] 2015 case [2015 SCC 7] to be a principle of fundamental justice. ... A Backgrounder … is available here. [Editor’s note: the “Orders Sought” section of the Federation’s Petition filed in the Supreme Court of B.C. on September 11, 2023, in addition to seeking interim relief, requests: 1. A declaration that sections 237.3 and 237.4 …of the … ITA … are inconsistent with the Constitution of Canada, and of no force or effect, to the extent that those sections apply to legal professionals. 2. ...