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News of Note post

Montminy – Federal Court of Appeal finds that employees enjoyed the ½ deduction on exercising their stock options notwithstanding an immediate sale of the acquired shares to the controlling shareholder

19 July 2017- 11:01pm Montminy – Federal Court of Appeal finds that employees enjoyed the ½ deduction on exercising their stock options notwithstanding an immediate sale of the acquired shares to the controlling shareholder Email this Content When a third-party purchaser agreed to acquire all the assets of Opco, the management employees agreed with the 100% shareholder of Opco (“Holdco”) that on the asset sale closing date, they would exercise their options to acquire common shares of Opco and immediately sell their newly-acquired shares to Holdco for an agreed cash sale price. ... He also found that providing the ½ deduction under s. 110(1)(d) to the taxpayers accorded with the broader context of the stock option rules. ...
News of Note post

Stonehouse Group – Ontario Court of Appeal considers “the principle that governments have the right to legislate illogically” to be “not … persuasive”

25 January 2021- 11:10pm Stonehouse Group – Ontario Court of Appeal considers “the principle that governments have the right to legislate illogically” to be “not … persuasive” Email this Content As a result of being reassessed to deny the carryback of a loss, the taxpayer was required to pay the reassessed taxes – but, following success in its objection, later was refunded the tax. ... It is also not a principle of statutory interpretation to be readily invoked. … The language in s. 79(7) is not unambiguous when read in its entire context. While it is not necessary to resort to it in this case … there remains “a residual presumption in favour of the taxpayer” …. ...
News of Note post

Yao – Tax Court of Canada excludes an “expert report” of an immigration lawyer – but admits reports of sociology and psychology professors

3 March 2022- 11:53pm Yao – Tax Court of Canada excludes an “expert report” of an immigration lawyer – but admits reports of sociology and psychology professors Email this Content In the context of a challenge under s. 15 of the Charter to the denial of child tax benefits to refugee claimants, Bocock J admitted, as expert reports, two reports of a sociology and psychology professor; on the basis that they could be helpful to the Court in determining whether the refugees were a relevantly disadvantaged group. ... The Queen, 2022 TCC 23 under General Concepts – Evidence. ...
Current CRA website

Chapter 6 - 8303, 8308 & 8409 – Pension Adjustments & Annual Information Returns

Chapter 6- 8303, 8308 & 8409 – Pension Adjustments & Annual Information Returns 6.1 8303(6) – Qualifying Transfers 6.2 8303(7) – Deemed Payment 6.3 8303(10) – Benefits in Respect of Foreign Service 6.4 8308(7) – Loaned Employees 6.5 8409(1) and (2) – Annual Information Returns 6.1 8303(6) – Qualifying Transfers Subsection 8303(6) of the Regulations defines for the purposes of the description of C in the formula in subsection 8303(3) (basic PSPA calculation), the description of D in the formula in subsection 8304(5) (modified PSPA calculation) and the description of B in the formula in subsection 8304(10) (IPP PSPA calculation), the amount of an individual’s qualifying transfer made in connection with a past service event. ... Cross reference: Deemed Registration – 147.1(3) 6.3 8303(10) – Benefits in Respect of Foreign Service Subsection 8303(10) of the Regulations allows the CRA to exclude past service benefits provided for a period of foreign service from PSPAs. ... Cross references: Participating Employer – 147.1(1) Pension adjustment limits – 147.1(8), 147.1(9) Eligible Service – 8503(3)(a) Maximum Benefits – 8504(1) Additional Compensation Fraction – 8507(5) 6.5 8409(1) and (2) – Annual Information Returns The plan administrator will have to file either: a joint annual information return by the date prescribed under the pension benefits legislation of a participating provincial pension supervisory authority; or for a non-participating pension supervisory authority a Form T244, Registered Pension Plan Annual Information Return, within 180 days of the plan's year-end. ...
Tax Interpretations Translation

15 November 2006 External T.I. 2006-0190041E5 F - Biogas / Codigestion Process / Produced for Sale -- translation

15 November 2006 External T.I. 2006-0190041E5 F- Biogas / Codigestion Process / Produced for Sale-- translation ...
Tax Interpretations Translation

15 December 2006 External T.I. 2006-0182471E5 F - Intérêts " explicitement identifiés " -- translation

15 December 2006 External T.I. 2006-0182471E5 F- Intérêts " explicitement identifiés "-- translation ...
GST/HST Ruling

17 January 2013 GST/HST Ruling 130479 - […] – Place of supply [in a Province] – [Intangible Personal Property and Services]

The [Organization] is the national […] for […]. The [Organization] is registered for GST/HST purposes. 2. The [Organization] was incorporated to pursue the following objectives: […] 3. […] 4. ... The [Organization] sponsors […] conferences held in various locations in Canada. […]. ...

Bekesinski – Tax Court of Canada finds that a director who likely backdated his resignation should prevail – in part, because the Crown did not plead the backdating

20 August 2014- 11:05am Bekesinski – Tax Court of Canada finds that a director who likely backdated his resignation should prevail – in part, because the Crown did not plead the backdating Email this Content Campbell J granted the taxpayer’s appeal from a director’s liability assessment under s. 227.1 on the basis that he had resigned more than two years previously, notwithstanding that, "in all likelihood, the Appellant backdated the Resignation. ... The Queen, 2014 TCC 245 under General Concepts – Onus and s. 227.1(4). ...
News of Note post

Loupy’s – Tax Court of Canada confirms that a backdated GST registration has retroactive effect – and that winding-down operations qualified a de-registrant as a “registrant”

12 December 2016- 11:39pm Loupy’s – Tax Court of Canada confirms that a backdated GST registration has retroactive effect – and that winding-down operations qualified a de-registrant as a “registrant” Email this Content When the operator of a restaurant ceased operations due to a termination of its lease, it applied for and was granted a revocation of its GST and QST registrations. ... Favreau J found that, notwithstanding the revocation of its revocation, the taxpayer was still a “registrant” – whose definition includes a “person who is required to be registered”- given that it still held equipment which it was seeking to sell (some of which it sold eight months’ later). ...
Miscellaneous severed letter

7 October 1990 Income Tax Severed Letter - Technical amendments — draft legislation on July 13, 1990 — Clause 31(8) — trusts

7 October 1990 Income Tax Severed Letter- Technical amendments — draft legislation on July 13, 1990 — Clause 31(8) — trusts Unedited CRA Tags none Dear Sirs: Re: Clause 31(8) Technical Amendments- Income Tax Act Draft Legislation- July 13, 1990 This is in reply to your letter dated July 19, 1990 wherein you requested our confirmation of your understanding on the above subject matter in a situation where an arriving immigrant sets up a non- resident discretionary trust and funds the trust with a loan. ...

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