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. … There are times when it is tax-advantageous to trigger a capital gain under subsection 48.1(1) even if the shares are not QSBC shares—for instance, to utilize tax attributes such as expiring losses. Potential for TOSI where making s. 38.1 election (p. 5) Under the new rules, taxable capital gains subject to TOSI are no longer limited to transactions under the purview of subsections 120.4(4) and (5). … [T]he expanded definition of "split income" includes taxable capital gains from the disposition of all non-QSBC private corporation shares realized, or deemed to be realized, by most Canadian residents. ...

. … AAII is calculated as if no FAT were deducted; therefore, FAPI earned by a Canadian-resident corporation would be considered AAII, irrespective of FAT paid by the relevant CFA on the FAPI. ... Therefore, FAPI earned by a CFA that is associated with the Canadian corporate taxpayer may be counted twice toward the new passive income restriction. … ...

…[O]n the basis of a literal interpretation of the affiliated entity rule … all companies everywhere in the world would have to participate in the joint election. ... As well, it would need signatures on the joint election from authorized representatives of all of the corporations. … Example of application of s. 125.7(4)(b) election to an affiliated group with a recent addition (p. 2) Example: Affiliated Group That Is Different from Prior Year [F]our entities meet the definition of an affiliated group in March 2020, but one of the entities was newly incorporated in 2020 …. ...

" There should be a specific tax debt that is being avoided (pp. 4-6) The reference in s. 160(5)(a)(ii) to a test of it being reasonable to consider that one of the purposes of the transaction or series was “to avoid … liability … for an amount payable under this Act” also sets too low a threshold and should be re-framed to refer to a demonstrable current or future anticipated tax debt of the transferor that would otherwise be avoided, determined at the beginning of the applicable series of transactions. ...

XIX are to be interpreted consistently with the common reporting standard rules published by the OECD, unless the context otherwise requires – and a similar provision appears in the anti-hybrid mismatch rules, the draft reporting rules on digital platform operators and in s. 3 of the Pillar 2 implementation legislation. Although this by itself would not have much impact (Canada’s tax treaties are interpreted in light of the OECD commentaries where relevant, without a specific provision to that effect), what is more significant is that these rules refer to the relevant OECD recommendations “as amended from time to time” – which raises the possibility of an interpretive expansions of the rules in the Act through OECD later-in-time materials. ...

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. ... The obligation for legal counsel to report confidential information to the CRA also violates the protection from unreasonable search and seizure in section 8 of the Charter. … The Government of Canada has consented to a 30-day injunction suspending application of the provisions to members of the legal profession, pending a hearing on the Federation’s injunction application. ...

(c)(iv) does not expressly address when eligible group entity status is tested, and refers to “an eligible group entity in respect of the taxpayer for the taxation year ” even though the eligible group entity definition provides a point-in-time test – perhaps an interest payment made by an entity is relevant under s. ...

. … [I]n British Columbia, the restriction only applies to "a record evidencing indebtedness of the person to whom shares are to be issued" (i.e., a promissory note issued by the subscriber)…. ... Ct.),,,] In Welling's view, the use of the phrase " shall not be issued" in s. 25(3) of the CBCA (and its provincial equivalents) means that inadequate consideration results in a nullity as between the issuer corporation and the registered holder. ... MNR [fn 16: …92 D.T.C. 2123…] ….. Nullification was used in the recent Federal Court of Appeal case St Arnaud v. ...

. … [I]n British Columbia,, the restriction only applies to "a record evidencing indebtedness of the person to whom shares are to be issued" (i.e., a promissory note issued by the subscriber)…. ... Ct.),,,] In Welling's view, the use of the phrase " shall not be issued" in s. 25(3) of the CBCA (and its provincial equivalents) means that inadequate consideration results in a nullity as between the issuer corporation and the registered holder. ... MNR [fn 16: …92 D.T.C. 2123…] ….. Nullification was used in the recent Federal Court of Appeal case St Arnaud v. ...

. … Finance should consider amending the Act to permit the subsection 111(12) loss to be carried forward after the AoC to offset a later related subsection 40(11) gain. ... This debt was issued when the Canadian dollar was at par, and now US$1.00 = CDN$1.30. ... On a net basis, XCo is economically advantaged by CDN$74 million — it borrowed the equivalent of CDN$100 million and is only required to repay the equivalent of CDN$26 million. ...