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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. ...

From 1978 on, this lead to all sorts of preferred share rules – the term preferred share rules, the guaranteed and short-term preferred share rules, collateralized preferred shared rules, leading all the way up through that decade, to the taxable preferred share rules in 1987. ... There was this view that we were legislating by press-release – every fortnight, we were dealing with something else. ... Reading the Wild case, it seems inconsistent with the expressed intention of Parliament – but I also appreciate the legislative concern that the decision identified. ...

That subclause provides that, if a particular foreign affiliate of a taxpayer provides services to another foreign affiliate of the taxpayer, then, to the extent that amounts paid by the other foreign affiliate in consideration for the services are deductible in computing its foreign accrual property income ("FAPI") (as defined in subsection 95(1) of the Act), these amounts are deemed to be income of the particular foreign affiliate from a business other than an active business – and are therefore included in the particular foreign affiliate's FAPI. ... Yours sincerely, Brian Emewein General Director – Legislation Tax Policy Branch ...

The February 4, 2022 draft legislative proposals regarding s. 160 planning; audit authority and enhanced trust reporting; as well as the interest measure: Finance is working through the comments – see also below. ... McGowan: All of the following examples are subject to solicitor-client privilege – reporting would not be required where it would breach privilege. ... There is limited flexibility to deviate from the Model Rules – we do not know yet precisely how much latitude we have, and we hope for further guidance soon. ...

Pillars 1 and 2 process International tax has been a key priority in recent years – including the “Pillars project.” ... Detailed blueprints were released and consulted on a year ago in October, but these did not necessarily reflect an agreed path forward, especially on Pillar 1 – which the previous US administration was not prepared to sign on to. ... Pillar 1 is quite novel, essentially adopting a formula allocation for a subset of profits of large MNE groups determined using accounting values – at least three sources of novelty. ...

On ratification, which will occur after all domestic procedures have been completed, countries will have to deposit their final reservations and notifications – so things can change between signature and ratification without any implications. ... A country can remove reservations – and generally that would mean adding or taking on more provisions from the MLI, but they cannot add reservations. ... The pertinent wording is: … at any time at or after the time … an obligation to pay or credit an amount as … a dividend on the shares, either immediately or in the future and either absolutely or contingently …. ...

The word “ control” might conceivably refer to de facto control by "one or more shareholders whether or not they hold a majority of shares. | am of the view, "however, that in section 39 of the Income Tax Act, the word “controlled” contemplates the right "of control that rests in ownership of such a number of shares as carries with it the right to a "majority of the votes in the election of the Board of Directors. ... C., at page 15, says: " ">The owners of the majority of the voting power in a company are the persons who are in ">effective control of its affairs and fortunes. ... Therefore, the rental income earned on real or immovable property in Canada would be included in the computation of a deemed resident trust’s income under Part |. ...

If the individual had more adult children, the benefits of sprinkling would increase – and if there were no adult child, the benefits would be reduced. ... As we know, the reasonableness concept is not new to the Income Tax Act – which is not to say, of course, that there are not challenges in applying this approach in the context of dividends. ... We feel this is less of a misunderstanding than an apples-and-oranges comparison – since the analysis leads to a 73% tax-rate, the focus is strictly on the nominal amount of investment income. ...