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Similarly, the definition of "principal residence" in section 54 states that it is a residence “owned, whether jointly with another person or otherwise, … by the taxpayer”. ...

Trevor McGowan – The idea is that the hallmarks in s. 237.3 would be essentially unchanged – confidentiality, premium or contingent fees, and contractual protections. ... Tax loss consolidation Shawn Porter – Moving then to tax loss consolidation. ... Group Ratio Shawn Porter – Not every country has adopted a group ratio. ...

Email this Content Finance Comfort Letters 2019 Link Affected legislation Principal topics Dec 2 Cross-Border Surplus Stripping & Graduated Rate Estates s. 212.1(6)(b) exception to s. 212.1(6)(b) look-through rule for graduated rate estates Sept 4 Principal Residence Exemption for Trusts s. 54 – principal residence – (c.1)(iii.1)(B) extend “principal residence” status for QDTs where an inter vivos trust Sept 3 Deductibility of Mining Taxes s. 20(1)(v), Reg. 3900(2), s. 152(4) removal of statute-barring where increase in mining taxes Aug 26 “Advantage”: Exclusion for Investment Management Fees “Advantage”: Exclusion for Investment Management Fees s. 207.01(1) definition of "advantage" and investment management fees of registered plans July 29 Eligible Capital Property (ECP) Transitional Issue s. 14(1) eligible capital amount recognition grandfathering of deferred proceeds from ECP disposition July 29 Functional currency tax reporting- currency of Japan s. 261(1) definition of ‘qualifying currency” designation of yen as qualifying currency 2018 Link Affected legislation Principal topics May 11 Saskatchewan Pension Plan- Tax Treatment of Variable Benefit Portion s. 146(21) et seq. variable benefits paid out of specified pension plan to qualify re pension income credits and income splitting and subject to Reg. 8506 May 1 repayment of back-to-back loans under the upstream loan rules s. 90(14) deemed B2B loan repayment deemed repayment of deemed loan under s. 90(7) similarly to ss. 15(2.18) and (2.19) 2016 Link Affected legislation Principal topics Dec 3 Foreign accrual property income resulting from the application of paragraph 95(2)(b) of the Income Tax Act to inter-affiliate payments for services s. 95(2)(b)(i)(B)(I) base erosion rule proposed extension of s. 95(2)(a)(ii)(D) safe harbor to inter-FA fees that are deemed FAPI under s. 95(2)(b)(i)(B)(I) 2015 Link Affected legislation Principal topics Nov 16 Spousal, alter ego and similar trusts s. 104(13.4) beneficiary income inclusion s. 104(13.4)(b) not to apply unless joint election joint election by trust and graduated rate estate and deceased died before 2017 – trust allocation of post death donations to s. 104(13.4)(a) year 2014 Link Affected legislation Principal topics Dec 23 The recent LRE amendments s. 251.2 loss restriction events s. 251.2(3)(f) safe harbour for unit redemptions – due date extensions for trust short year- loss restriction event only where actual beneficiary change [see also 2014-0534841C6 F]- application dates ...

However, we identified a number of issues – some of which were not borne out by the data and have been dropped. ... As noted in the paper, the intention was not do all of the proposals – indeed, some of them were mutually exclusive. ... The Greenhouse Gas Pollution Pricing Act – famously “not a tax” – has a preamble. ...

GAAR Consultation He noted that the August 9 GAAR consultation paper stated at its outset that Finance thinks the GAAR is working reasonably well – but, even so, it could do with a tune-up after more than 30 years of practice, experience, tax administration and case law. ... Although the paper sought to cover the possible proposals in a balanced manner, even being transparent where a possibility was perhaps not workable or necessary, some of the proposals still prompted strong reactions – all of which is an expected and useful part of the consultation process. ... Although the judicially developed analytical framework is reasonably sound, there are some cases that may benefit from a further statutory “nudge” with regard to economic substance – and the case was made for this benefiting the efficiency of the system overall. ...

Its structure differs in some respects from the rest of the MLI – it is a single cohesive arbitration provision and it does not have compatibility clauses with respect to each article. ... We learned quickly, when discussing that among European and other colleagues, that that does not mean much to them – they are not very familiar with salary arbitration in North America. ... Independent opinion is based on a precedent from the EU Arbitration Convention, and it would effectively work more like a court proceeding – with evidence rules and oral hearings. ...

We are also plugged into Dunn & Bradstreet data, and have an iteration of Watson as an appliance running in the background. ... How do transfer pricing audits work – how do they work in Canada, and how do they work internationally? ... The program cannot work without that – it is something we lost, and we need to put it back in the system. ...

Since then, in addition to holding that this structure is primarily entered into to obtain a tax benefit and would not be undertaken by persons dealing at arm’s length, CRA also uses a new term — “commercial irrationality” — which is also well known in transfer pricing circles. ... Notices are not limited to a bad news – they’re a useful way for those of us in the Compliance Programs Branch to communicate directly with tax professionals as opposed to the general public, so we can be a bit more technical sometimes and just talk about administrative positions that we are taking. ...

Filings to amend the tax position of the trust and the beneficiary are as follows: • The trust would file Form T3A "Request for a Loss Carryback by a Trust" in connection with the loss year to request the loss be carried back to the prior year. • The trust would file Form T3-ADJ "T3 Adjustment Request" for the prior year to reflect a late subsection 104(13.1) or (13.2) designation so as to amend the trust's T3 Return. • The trust would issue amended T3 slips to the beneficiary for that prior year, reducing the income allocated. • The beneficiaries would file a Form T1-ADJ "T1 Adjustment Request" to reflect the revised T3 slip and to amend the T1 Return. ... Further, the settlor /grantor can exercise his / her power to revoke the trust at any time. The settled property often includes all personal, tangible, intangible and real property of the settlor / grantor. ...

Canada has particular challenges going down the corporate route – only 10% of Canadian corporations are registered federally, and the rest are distributed among the provinces and territories. ... We are still working through all the design issues – I think this group can appreciate the kind of gyrations we’re going through in trying to develop an appropriate measure dealing with passive investment income – so we are still working on those key design elements and we will be looking at all the planning deferral benefits that arise with respect to passive investment income. ...