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15 September 2020 IFA Roundtable Q. 5, 2020-0853401C6- IFA 2020 Q5: TPM-17 and COVID-19-- summary under Paragraph 247(2)(a) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2)- Paragraph 247(2)(a) Canadian governmental COVID assistance likely will not reduce cost under cost-plus transfer-pricing methods TPM-17 provides that the cost base should not be reduced by government assistance unless there is reliable evidence that arm’s length parties would have done so – so that it generally is presumed that the Canadian taxpayer will keep the assistance. ...

CRA stated that it was “not prepared to take an administrative position to consider that subsection 247(7) would apply in respect of the loan between the FA and LP ….” ...

A) and the two children – following which the shares of Mr. A and of the children would be transferred on a s. 85(1) rollover basis into a holding company controlled by Mr. ...

CRA stated, regarding the requirement that there have been a written agreement entered into before October 9. 2020: [W]hile there is no requirement that the documents be signed … the written documents must show a clear intention to create a binding and enforceable contractual relation, outline all the essential terms and conditions of the agreement, and demonstrate an acceptance in writing by both parties of the terms and conditions. ...

CRA stated that this was “possible … assuming that the Lease includes the same enforceable and binding rights and obligations, and terms and conditions, as the [letter agreement].” ...

…[T]here are other factors that may affect [this] determination …. For example, the sublease itself may contain a condition stipulating that the agreement would not take effect until the signature of the landlord was procured. ...

Therefore, the 87(1)(a) condition would be met – all property of the predecessor corporation becomes property of the new corporation by virtue of the amalgamation. ...

CRA stated: … [I]t appears that the requirements to use the rule in paragraph 125.7(4)(d) could be met since all of Opco’s revenue would be considered to be derived from persons with which Opco does not deal at arm’s length (the participants of the joint venture, Holdco 1 and Holdco 2). ...

3 November 2021 CTF Roundtable Q. 14, 2021-0911951C6- Failure to properly file a T1135-- summary under Foreign Affiliate Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Foreign Affiliate s. 95(1) FA definition is broader than under s. 233.4 The T1135 form and related disclosure stated that specified foreign property “does not include … a share of the capital stock or indebtedness of a foreign affiliate,” without disclosing that the definition “foreign affiliate” for these purposes is narrower than the definition in s. 95(1). ...

After preliminary transactions to distribute capital dividends and eligible dividends from the companies, the trusts were then to engage in pipeline transactions in which the Aco and Bco shares were to be transferred to a ULC Newco on a s. 85(1) rollover basis in consideration for notes and nominal value preferred shares with redemption values subject to a price adjustment clause, and then convert those notes to high-PUC shares of the ULC – and only after a number of years, might ULC be amalgamated with Aco and Bco (which would have been continued to the same jurisdiction as Aco and Bco). ...