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1 June 2025- 11:37pm CRA illustrates an ordering rule for determining whether s. 15(2.17) applies to a cross-border notional cash pooling arrangement – and doubts that the s. 15(2.6) exception applies Email this Content CRA indicated that anticipated frequent and ongoing movements under a notional cash-pooling arrangement would likely be considered to form part of a series of loans, repayments, and other transactions for s. 15(2.6) purposes. ...

9 June 2025- 11:45pm Shopify – Federal Court finds that s. 231.2(3)(b) currently did not authorize unnamed person requirements pursuant to treaty information-exchange Articles Email this Content Shopify was a Canadian corporation providing a software platform for online e-commerce transactions. ...

22 July 2025- 10:56pm Larocque Family Trust – Court of Quebec finds that s. 160 can apply to a s. 227.1 liability of a director who was not assessed therefor until well after the subject transfer Email this Content An individual (Larocque) was a director of a corporation (Construction LMA), engaged in the development of residential projects. ...

14 August 2025- 12:01am Vefghi – FCA confirms that whether a s. 104(19) dividend was received by a corporate beneficiary from a connected corporation is tested at the trust year end Email this Content Partway through its calendar taxation year, a family trust received a dividend from a family corporation, paid that dividend to a corporate beneficiary (also with a calendar year end) and in its return for that taxation year, made a s. 104(19) designation. ...

20 January 2022- 11:13pm Singapore Telecom – Federal Court of Australia finds that arm’s length parties would not have agreed to a loan having a significant participation feature Email this Content A Singapore-resident company (“SAI”) transferred the shares of a recently-acquired Australian telecom company (“SOPL”) to an Australian subsidiary (“STAI”) in consideration for common shares and $5.2B in unsecured notes which had a term of approximately 10 years and bore interest at a floating rate equal to the 1 year bank bill swap rate (“BBSR”) plus 1%, but multiplied by a gross-up factor of 10/9 to reflect that the interest was subject to withholding tax. ...

11 September 2024- 12:09pm Milgram – Federal Court finds that it has the jurisdiction to quash an abusive decision of CRA to assess, even though the resulting assessment was objected to Email this Content Milgram, a Liechtenstein-resident trust that had determined that it might be a deemed resident under s. 94, made a 2015 filing under the CRA voluntary disclosure program for its 2003 to 2014 taxation years (for which the financial information was still available), and in December 2015, the VDP officer accepted the disclosure. ...

VI, s. 22, which applied to “a supply of a service, made by a municipality … of... maintaining … a … sewerage … system”? CRA acknowledged that City of Brandon had found that this wording “is broad enough to include the ‘operation’ of a … sewerage … system,” but characterized what was going on here as instead being “the acceptance, treatment and disposal of … wastewater at the [other’s] municipal wastewater treatment facilities,” so that the exemption was unavailable. ...

Summary of Goldcorp Circular under Mergers & Acquisitions – Cross-Border Acquisitions – Inbound – Direct Target Acquisitions. ...

Summary of Intertain Circular under Public Transactions – Mergers & Acquisitions – Cross-Border Acquisitions – Inbound – Exchangeable Shares. ...

Agence du revenu du Québec, 2021 QCCQ 4379 under Reg. 1206(1) – CEDOE – para. (b), s. 18(1)(b) – capital expenditure v. expense – current expense v. capital acquisition, s. 66.1(6) – CEE – para. ...