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9 January 2024- 12:24am Brookfield Renewable Power – Court of Quebec reduces the deductible interest on loss consolidation loans from 14% to 8.75% Email this Content In connection with a September 2009 loss consolidation transaction between a “Lossco” in the Brookfield group (“BRPI”) and its “Profitco” subsidiary (“BEMI”): Two Newcos with nominal share capital were lent $2.25 billion and $0.525 billion by BRPI pursuant to unsecured demand notes bearing interest at 14%; Each Newco used the loan proceeds to subscribe for non-cumulative preferred shares of BRPI; On the same day, BEMI acquired the Newcos for a nominal amount and they were wound up into BEMI, so that BRPI held $2.275 billion of loans in its subsidiary, and BEMI held $2.275 billion of preferred shares of its parent; and The loans were left outstanding for approximately five months, then: BRPI declared and paid a dividend on the preferred shares to fund the payment of all the accrued interest on the loans, and those shares and loans were redeemed and repaid by way of set-off. ...

Expense- Contract or Option Cancellation cash settlement of employee stock options in connection with the privatization of the corporation was a capital expenditure 2002-03-15 4 April 2002 External T.I. 2001-0104065 F- PROVISION D'ENTREPRISE DANS UNE PROVINCE Income Tax Regulations- Regulation 2601- Subsection 2601(1) Quebec partner who retired and became an Ontario employee allocated the reserve inclusion under s. 34.2(5) wholly to Ontario 9 April 2002 Internal T.I. 2001-0112817 F- RESIDENCE PRINCIPALE- VENTE D'UN DUPLEX Income Tax Act- Section 54- Principal Residence- Paragraph (e) duplex land allocated between rental and principal residence generally based on the floor areas of the respective building portions 4 April 2002 Internal T.I. 2001-0113237 F- REMBOURSEMENT DE FRAIS MEDICAUX Income Tax Act- Section 118.2- Subsection 118.2(3)- Paragraph 118.2(3)(b) Quebec CIMAD qualifies as reimbursement of specific expenses 4 April 2002 External T.I. 2002-0123065 F- DOMMAGES-INTERETS Income Tax Act- Section 54- Proceeds of Disposition- Paragraph (b) compensation received by Jews for property seized 60 years previously was a windfall rather than proceeds of disposition Income Tax Act- Section 3- Paragraph 3(a) annuities or capital sums paid to victims of anti-Semitic persecution were not income ...

Section 206 provides that there can be such an amendment “provided doing so does not delay the proceeding and is not contrary to the interests of justice” but that “the amendment of a pleading must not result in an entirely new application having no connection with the original one.” ...

The ruling letter provides that the Arrangement Agreement was to state: DC2 and SpinCo will: a. covenant and agree with and in favour of each other that for a period of time after the Effective Date to be agreed upon, they will not (and they will ensure that their respective subsidiaries will not) take any action or enter into any transaction that could cause the transactions contemplated in the Plan of Arrangement or by the Arrangement Agreement to be taxed in a manner that is inconsistent with the rulings provided in this letter without obtaining another tax ruling or an opinion of a nationally recognized accounting firm or law firm that such action or transaction will not have such effect; and b. agree to indemnify each other for losses suffered or incurred as a result of or in connection with a breach or non-compliance with the covenant described in item (a) above. ...

As a result of that pipeline transaction, the estate ended up holding both preferred shares and a note of the corporation (the distributing corporation or DC) resulting from the amalgamation of the Newco used in connection with the pipeline transaction and Holdco. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2001-04-27 10 April 2001 External T.I. 2001-0078035 F- RAP PERSONNE DIVROCEE Income Tax Act- Section 146.01- Subsection 146.01(1)- Regular Eligible Amount- Paragraph (f) divorced individual was eligible notwithstanding ownership during their marriage of home by ex-spouse 12 April 2001 External T.I. 2000-0050655 F- ASSURANCE MUTILATION/INVALIDITE Income Tax Act- Section 148- Subsection 148(9)- Disposition- Paragraph (h) disability benefits under a policy providing life and accidental death and dismemberment insurance could be non-taxable Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account personal injury amounts received pursuant to life insurance policy not added to CDA 23 March 2001 Internal T.I. 2000-0056097 F- Roulement interne Income Tax Act- Section 84- Subsection 84(1) s. 84(1) deemed dividend where individual’s low-PUC common shares are exchanged with the corporation for high-PUC preferred shares and there is an s. 85(1) agreed amount at FMV 17 April 2001 External T.I. 2000-0056455 F- AVANTAGE IMPOSABLE-EMPLOYE Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) the distribution of employer shares to employees as beneficiaries of a discretionary trust is a s. 6(1)(a) benefit if it has the slightest connection to their employment 2 February 2001 Internal T.I. 2000-0058127 F- Convention d'émission d'actions follow-up in 2001-007939 F Income Tax Act- Section 7- Subsection 7(2) s. 7(2) could apply if shares were held by the employer for later acquisition by the employee 19 April 2001 Internal T.I. 2001-0069067 F- PENSION ALIMENTAIRE ACCORD ECRIT Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount submitted documents were not a written agreement ...

2 February 2025- 11:42pm Raiche – Court of Quebec finds that a suspended Quebec police officer had not severed his Quebec ties when he started living (except when in Quebec) with his son in Ontario Email this Content Raiche started living with one of his two sons in Petawawa Ontario when, in November 2015, he was suspended from his employment with the Quebec police force in connection with a criminal investigation of him. ...

That CRA (departing from 2019-0798861C6) confirm that the excluded disposition rule in s. 150(5)(b) will be satisfied where all Part I tax owing in respect of the TCP disposition is paid in connection with the issuance of a s. 116 certificate (so that no Canadian return filings- or filings in relation to a limited partnership- is required). ...

The taxpayer, which sold goods for a fixed price payable in instalments, paid reasonable meal allowances to its employees for their travel in connection with the sales (e.g., installations). ...

. … In order for the exemption to apply, it must be evident that there is some direct connection between the supply of the service of tutoring or instructing in question and the course approved for credit by, or the curriculum designated by, a school authority. ...