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8 May 2016- 10:26pm Non Corp Holdings – Ontario Superior Court of Justice rectifies the date of a capital dividend declaration to eliminate Part III tax Email this Content CCPCs generally can pay out ½ of capital gains as a capital dividend immediately after realization, whereas additions to the capital dividend account from sales of eligible capital property do not occur until the year end. ... In granting this rectification order (which was not opposed by CRA), Dunphy J stated that (in contrast to his Birch Hill decision, where the denied rectification “would have materially re-ordered the transaction in ways that nobody had considered at the relevant time”), here: There was a specific intention to allocate specific proceeds of a specific transaction to a specific tax account – the capital dividend account – to achieve a specific tax goal. ... A.G., 2016 ONSC 2737 under General Concepts – Rectification and s. 89(1) – capital dividend account – para. ...
News of Note post
10 June 2024- 11:50pm Burlington Loan Management – Upper Tribunal finds that Irishco’s purchasing a UK interest claim from Caymansco at a tax arbitrage price did not have Treaty-reduction as a main purpose Email this Content BLM was a substantial Irish-resident investment company, which had been acquiring proved claims in the administration of Lehman Brothers International (Europe) ("LBIE" – a UK resident) since 2011. ... HMRC denied BLM’s refund claim on the basis of Art. 12(5) of that Treaty, which excluded the application of Art. 12 “if it was the main purpose or one of the main purposes of any person concerned with the … assignment … to take advantage of … Article [12].” ... Summary of Revenue & Customs v Burlington Loan Management DAC [2024] UKUT 152 under Treaties – Income Tax Conventions – Art. 12. ...
Current CRA website
Farming Income and the AgriStability and AgriInvest Programs Harmonized Guide 2021 – Chapter 6 – Eligible capital expenditures
Farming Income and the AgriStability and AgriInvest Programs Harmonized Guide 2021 – Chapter 6 – Eligible capital expenditures On this page… Find out what an eligible capital expenditure is Find out what an annual allowance is Find out what a cumulative eligible capital account is Transitional rules – Undepreciated capital cost balance Transitional rules – Deemed gain immediately before January 1, 2017 Transitional rules – Dispositions of former ECP Transitional rules – Non-arm's length dispositions of former ECP As of January 1, 2017, the eligible capital property (ECP) system was replaced with the new capital cost allowance (CCA) Class 14.1 with transitional rules. ... Transitional rules – Deemed gain immediately before January 1, 2017 You may be able to include an amount in your income in a tax year that straddles January 1, 2017. ... For more information on changes to the ECP system, go to Explanatory Notes – Eligible Capital Property. ...
24 June 2014- 11:13am Henco – Tax Court of Canada finds that compensation received for a destroyed business was completely tax-free Email this Content The Ontario government capitulated to Six Nations protesters, who occupied the subdivision property of the taxpayer (Henco), by passing a by-law prohibiting any use of the property (thereby rendering it valueless and (per C. ... The Queen, 2014 DTC 1161 [at 3528], 2014 TCC 192 under s. 9 – compensation payments, s. 12(1)(x), s. 14(5) – cumulative eligible capital, s. 23, General Concepts – fair market value – land, and General Concepts – evidence. ...
Ruling summary
2018 Ruling 2018-0740931R3 F - deductibility of interest – convertible debentures -- summary under Subsection 20(3)
2018 Ruling 2018-0740931R3 F- deductibility of interest – convertible debentures-- summary under Subsection 20(3) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(3) s. 20(3) applicable to borrowed money used to redeem principal of convertible debentures A Canadian public company (ACo) will force the conversion of its outstanding convertible debentures, by issuing a notice to redeem them for their principal amount. ... It also ruled: Subsection 20(3) will be applicable to the portion of Loan 3 … corresponding to the aggregate principal amount of the outstanding Debentures … such that borrowed money will be deemed for purposes of the application of paragraph 20(1)(c) to be used for the purposes for which the outstanding Debentures were used or incurred. ...
SCC (summary)
Quebec (Agence du revenu) v. Services Environnementaux AES inc., 2013 DTC 5174 [at at 6466], 2013 SCC 65, [2013] 3 SCR 838 -- summary under Rectification & Rescission
., 2013 DTC 5174 [at at 6466], 2013 SCC 65, [2013] 3 S.C.R. 838-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission Quebec documents did not implement common intention to defer tax Riopel Facts Mr. ...
TCC (summary)
Allegro Wireless Canada Inc. v. The Queen, 2021 TCC 27 -- summary under Scientific Research & Experimental Development
The Queen, 2021 TCC 27-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development software development qualified as SR&ED The taxpayer provided a software platform to its clients to allow them to communicate remotely with their workers through wireless handheld devices used to access their employer’s computer system, in a great variety of applications. ... Agencies, found (at para. 194) that the taxpayer “was attempting to develop a new product (its platform) that would work seamlessly with a multitude of devices that used different operating software and ran on the various operating systems of [its] clients” and similarly (at para. 202) that the work undertaken by the taxpayer was "for the purpose of achieving technological advancements that would allow [it] to create a new and/or better product” found that the project had various challenging elements and that these challenges could not be resolved with routine engineering, so that it was instead required to experiment to come up with hypotheses of things that it could test also noted (at para. 209) the projects “were the same or similar to projects in respect of which the Appellant received grants from the National Research Council of Canada” Before allowing the appeal, he stated (at para. 208) … I have concluded that when the Appellant conducted the projects at issue, it formulated hypotheses specifically aimed at reducing the identified technological uncertainty, followed appropriate procedures on testing, including the formulation, testing, and modification of hypotheses, and maintained a detailed record of the hypotheses tested and results achieved as the work progressed. ...
TCC (summary)
Béton mobile du Québec Inc. v. The Queen, 2019 TCC 278 -- summary under Scientific Research & Experimental Development
The Queen, 2019 TCC 278-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development there can be reasonable certainty as to a successful outcome if the means of achieving it are uncertain The taxpayer (BMQ) used mobile concrete mixers to provide concrete at the site of construction or major repair projects. ...
Current CRA website
T2 Corporation – Income Tax Guide – Chapter 1: Page 1 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 1: Page 1 of the T2 return From: Canada Revenue Agency On this page... Identification Signing up for email notifications when filing your T2 return Line 001 – Business number (BN) Line 002 – Corporation's name Lines 010 to 018 – Address of head office Lines 020 to 028 – Mailing address Lines 030 to 038 – Location of books and records Lines 040 and 043 – Type of corporation at the end of the tax year Lines 060, 061, 063, 065 – To which tax year does this return apply? ... Line 079 – If an election was made under section 261 Lines 080 to 082 – Is the corporation a resident of Canada? ...
News of Note post
8 March 2024- 12:01am 3295940 Canada – Federal Court of Appeal finds no abuse in a tax plan producing the same gain as if the ultimate shareholder had directly used its high outside basis for its investment Email this Content The taxpayer (3295) was a holding company with a minority shareholding in a target company (Holdings) with a low ACB, whereas 3295’s parent (Micsau) had a high ACB for its 3295 shares. ... Thus, the “series’ overall result [was] consistent with the object, spirit and purpose of the capital gains regime as previously identified by this Court—that is, to tax real economic gains: Triad Gestco … “. ...