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Results 131 - 140 of 154 for connection

1074022 B.C. Ltd. v Li - BCSC finds that CRA could be directed to pay an excess s. 116 remittance to the taxpayer’s secured creditors

Ltd. v Li- BCSC finds that CRA could be directed to pay an excess s. 116 remittance to the taxpayer’s secured creditors Email this Content No s. 116 certificate was obtained on a court-approved sale of a Vancouver property (arising in connection with foreclosure proceedings) by the Hong Kong owner (Mr. ...

Non-resident realty investors may be subject to Quebec rules imposing double taxation

On a literal reading of the taxable Quebec property definition, that term can include a closely-held company share that derives its value principally from a Canadian resource property, even where there is no connection to Quebec, e.g., shares of a Canadian corporation holding only Alberta exploration rights. ...

Emergis – Tax Court of Canada finds that U.S. withholding tax applicable to a tower structure did not generate a s. 20(12) deduction

Given the flow of funds in this tower structure, there is some connection between the interest income paid by USGP and the dividends paid by LLC to USGP, which were reclaimed and reported by Emergis through its partnership interest in USGP. ...

CRA finds that the new ETA s. 179(9) drop shipment rule does not affect whether a non-resident lessor is carrying on business in Canada

If CRA instead started with the proposition that s. 179(9) deemed the non-resident to no longer have any significant transactional connection with Canada, then it could have reached the opposite conclusion. ...

G E Financial Investments – First-Tier Tribunal finds that a deemed US resident was not a US treaty resident

Brooks J effectively applied commentary- that the quoted wording requires “effective personal attachment to a territory,” and the effective finding in Crown Forest that full or worldwide taxation is a necessary feature of the connecting criterion but is not sufficient of itself- to find that the mere stapling of the GEFI stock did not give rise to the required connection to the U.S., so that GEFI was not a US treaty resident. ...

Frank C. Smith Medicine Professional Corp – Federal Court finds that it was not unreasonable for CRA to request information under s. 231.1 (not 231.6) on a Buffalo USB key

After having indicated that the reasonableness of the letters turned on a test of whether there may be considered to be “a rational connection … between the information sought and the administration and enforcement of the ITA,” Fothergill J rejected a submission that the request letters sought foreign-based information and that they should have been issued under s. 231.6, stating: I am satisfied that Dr. ...

BMO Nesbitt Burns – Federal Court rejects a claim that providing a full spreadsheet would breach privilege or a requirement not to disclose uncertain tax positions

28 March 2022- 12:26am BMO Nesbitt Burns – Federal Court rejects a claim that providing a full spreadsheet would breach privilege or a requirement not to disclose uncertain tax positions Email this Content CRA brought an application pursuant to s. 231.7 seeking an order requiring BMO Nesbit Burns (“BMONB”) to provide an unredacted version of a spreadsheet in connection with CRA’s audit of suspected dividend rental arrangement transactions of BMONB. ...

PC Bank – Tax Court finds that loyalty points were redeemed by a credit card issuer in the course of its financial services business so that no ITCs were available

Hogan J (who was dismissive of the relevance of some taxable amounts charged by PC Bank to Loblaws in connection with the redemptions) stated: PC Bank issued the PCB Points to generate revenue from its PC MasterCard portfolio. ...

Arrbab - Court of Appeal of England and Wales restrictively interprets a power accorded in subordinate legislation to amend the primary legislation

28 January 2024- 11:41pm Arrbab- Court of Appeal of England and Wales restrictively interprets a power accorded in subordinate legislation to amend the primary legislation Email this Content Section 124 of the Finance Act 2008 (UK) provided inter alia that Treasury could by statutory instrument make an order in connection with appeals against HMRC decisions which amended the provisions of any Act, provided that a draft of the order had been laid before and approved by resolution of the House of Commons. ...

We have translated 8 more CRA severed letters

Bundle Date Translated severed letter Summaries under Summary descriptor 2024-01-31 2023 Ruling 2022-0955451R3 F- Post mortem pipeline Income Tax Act- Section 84- Subsection 84(2) conventional post-mortem pipeline transaction 22 June 2023 External T.I. 2018-0746741E5 F- Eligible dividend allocation Income Tax Act- 101-110- Section 104- Subsection 104(19) eligible and non-eligible dividend can be wholly designated to two respective beneficiaries Income Tax Act- 101-110- Section 104- Subsection 104(13) a discretionary trust can wholly allocate each of an eligible and a non-eligible dividend to each of two recipient beneficiaries 2002-04-26 22 May 2002 Internal T.I. 2001-0106577 F- APPARIEMENT DES REVENUS ET DEPENSES Income Tax Act- Section 9- Timing following Canderel, an upfront payment made under a multi-year supply contract is currently deductible 14 May 2002 Internal T.I. 2001-0109517 F- SECTION DE LA LOI248(28) Income Tax Act- Section 248- Subsection 248(28) disallowance of interest deduction to partnership on loans to corporate partners whose amount was included in their income under s. 15(2), was not contrary to s. 248(28) 8 May 2002 Internal T.I. 2002-0135737 F- REGIME DE CONGE A TRAITEMENT DIFFERE Income Tax Regulations- Regulation 6801- Paragraph 6801(a)- Subparagraph 6801(a)(vi) s. 6(11) income recognition when apparent that the leave would not commence within 6 years/ Reg. 6801(a)(vi) does not to extend 6-year period but deals with leaves over one year 2002-04-12 3 May 2002 External T.I. 2001-0110145 F- avantage imposable-vetements Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) reimbursing a professor for a briefcase needed in connection with work would be non-taxable 3 May 2002 External T.I. 2002-0132615 F- PERTE DECOULANT D'UN PAIEMENT A UN RPDB Income Tax Act- Section 147- Subsection 147(8) creation of a business loss from making a DPSP contribution is not necessarily inconsistent with the DPSP rules 1 May 2002 External T.I. 2002-0133145 F- RAP- BAIL & ACTIONS Income Tax Act- Section 146.01- Subsection 146.01(1)- Qualifying Home unit consisting of a leasehold interest and shares of the corporation owing the property could qualify as qualifying home ...

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