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Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership Quaere whether beneficiary is beneficial owner (pp. 20:7-8) Some commentators argue that a beneficiary of a trust is the beneficial owner of trust property, while others consider a beneficiary to have only a personal right to compel the trustee to administer a trust pursuant to the terms of the trust agreement. [fn 30: … (2003) Canadian Tax Journal 311-54 … 401-53] [T]here will be a bare trust where the trustee—in all dealings relating to the trust property—has no discretion and is subject to the control of another person. ...

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Subsection 93(1.3) Summary Under Tax Topics- Income Tax Act- Section 93- Subsection 93(1.3) Unavailability of s. 93 regime where partnership interest disposed of (p. 20:49) [S]ubsection 93(1.3) applies only where the shares disposed of are EP. ... In such a case, the benefits offered by the section 93 election dividend election are not available, and an actual dividend must be paid in order for a CRIC to benefit from any underlying FA surplus (which may have foreign withholding tax consequences …). On the other hand, the loss denial rules in section 93 … do apply where a partnership interest is sold. ...

.-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission ...

.-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Includes (at pp. 751-754) a discussion of the Clayton rule. ...

.-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission ...

", Tax Notes International, 16 August 2004, p. 631-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission Discussion of Snow White Productions Inc. v. ...

Arnold, "Timing and Income Taxation: The Principles of Income Measurement for Tax Purposes", Canadian Tax Paper, No. 71, Canadian Tax Foundation, July 1983-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt See chapter 3 entitled "Cash Basis Accounting: The Concepts of Receipt and Payment". ...

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 Subsection 272.1(8) Summary Under Tax Topics- Excise Tax Act- Section 272.1- Subsection 272.1(8) Self-assessment within a FMV range (p. 14) [I]f the transfer pricing model … were adopted, a transfer pricing-like study would often generate a range of acceptable arm’s length prices for particular management and administrative services. ...

Tim Barrett, Andrew Morreale, "Foreign Affiliate Update", 2019 Conference Report (Canadian Tax Foundation), 35: 1 – 53-- summary under Paragraph 15(1.5)(c) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1.5)- Paragraph 15(1.5)(c) Undesirability of gain if demerger of top-tier affiliate Where the demerger is of a top-tier affiliate whose FMV exceeds the net surplus and the basis in its shares, a gain will result to the Canadian shareholder – so that it may be advantageous to transfer the shares of the top-tier affiliate into a new non-resident holding company under s. 85.1(3) prior to the demerger. ...

Jessica Fabbro, "Dying to Donate – Determining Charitable Donation Tax Credits on Death after 2015", Tax Topics, Wolters Kluwer, Number 2249, April 16, 2015-- summary under Subsection 118.1(5.1) Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(5.1) Allocation of gifts on death (p.2) The amended Legislation will no longer deem all charitable gifts to have been made by the deceased immediately prior to the deceased's death. ... [fn 12: Subsection 118.1(5), effective 2016] … While this would seemingly eliminate the deceased's ability to claim the CDTC [charitable donations tax credit] on his or her terminal tax return or penultimate tax return, the definitions of "total charitable gifts", "total cultural gifts", and "total ecological gifts" have all been amended to allow the executors to allocate the charitable gifts made by the deceased on death between the deceased and the deceased's estate, provided that the deceased's estate is a "graduated rate estate" at the time the gift is made. ... [fn 20: … 2014-0555511E5 …] As a result, after the amendments are in force, spouses will have less flexibility with respect to the allocation of charitable gifts between themselves than they did under the CRA's former administrative position. ...