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“No significant assessments have come to light in connection with the treatment of the servicing...since... ...

In order to rely on the exemption from withholding tax under the Canada-US treaty, the Canadian requests a representation from the licensor that there is no licensing arrangement that may be caught by the connection test in the back-to-back rules. ...

10 May 2017- 12:01am Rio Tinto Alcan – Tax Court of Canada confirms the validity of a reassessment made without a proper audit in order to beat statute-barring Email this Content When the normal reassessment period for one of the taxation years of Rio Tinto Alcan (RTA) was about to expire, CRA had not received any waiver from RTA in connection with the items under review (SR&ED expenditures incurred through a joint venture, whose manager was uncooperative with CRA) because the form of waiver demanded by CRA was unreasonable. ...

14 November 2017- 12:13am Scott – Tax Court of Canada finds that compensation to former Nortel employees for loss of life insurance was non-taxable Email this Content In connection with the Nortel asset distributions, a Nortel health and welfare trust made lump sum payments in 2011 to various beneficiaries in satisfaction of their entitlement to payments under the trust. ...

The Directorate found that the lump sum was not a royalty on general principles and, in light of Farmparts (which stated that an exclusive right to buy and sell could, “under no circumstances, be said to constitute the use or the right to use” the product) likely also was not caught by s. 212(1)(d)(i), nor did the Directorate recommend challenging the characterization under the agreement of the licence of a trademark as being gratuitous (as the “Distribution Agreement does not contemplate an extensive use of the trade-mark, but only limited use in connection with the distribution, promotion and advertising of the product.”) ...

This entailed accepting the proposition that fees incurred in connection with the advisability of acquiring or spinning-off a whole company qualified as being paid for “advice as to the advisability of purchasing or selling a specific share … of the taxpayer.” ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2013-03-20 19 December 2012 External T.I. 2011-0425581E5 F- CII- régions admissibles-Montérégie-Rive-Sud Income Tax Act- Section 127- Subsection 127(9)- Specified Percentage description of qualifying ITC regions (which exclude Montérégie South Shore) 24 October 2012 External T.I. 2012-0443721E5 F- Compensation- vente d'un immeuble Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Damages taxpayer need not have attempted to prevent the act or omission resulting in the damages 20 February 2013 External T.I. 2012-0473051E5 F- Frais de gestion versés à un conjoint Income Tax Act- Section 67 determining reasonableness of spousal management fee entails a “comparison to an amount paid for similar services according to industry standards” 27 November 2012 External T.I. 2012-0445941E5 F- Action déterminée de petite entreprise Income Tax Act- Section 44.1- Subsection 44.1(1)- Qualifying Disposition shares issued to a family trust do not qualify as "eligible small business corporation shares" 25 February 2013 Internal T.I. 2012-0440371I7 F- Changement d'usage- Duplex Income Tax Act- Section 45- Subsection 45(3) s. 45(3) election unavailable for partial change of use (duplex going from 50% to 100% personal use) 11 February 2013 External T.I. 2012-0469441E5 F- Aire de plancher- fabrication et transformation Income Tax Regulations- Regulation 1100- Subsection 1100(1)- Paragraph 1100(1)(a.1) washrooms and cafeteria included- along with office if a connection with the M&P personnel ...

Art. 12 of the Canada-U.K Treaty exempted copyright royalties, but there was an exclusion from this exemption for payments in respect of motion pictures or of works on film, videotape or other means of reproduction for use in connection with television broadcasting. ...

Rousseau left Quebec solely for work purposes and that he never had the intention to sever his connections with Quebec, which was the place with which he maintained his strongest links between 2003 and 2011. ...

14 November 2018- 11:44pm CRA confirms that amounts derived from a related business do not include capital gains from the passive investment of the dividends therefrom Email this Content S. 120.4(1.1)(d) provides that an amount derived directly or indirectly from a business includes an amount that: is derived from the provision of property or services to, or in support of, the business, or arises in connection with the ownership or disposition of an interest in the person or partnership carrying on the business, or is derived from an amount described [above] Notably, it does not reference an amount arising from the disposition of property whose acquisition was funded with dividends from the business. ...