Search - connection

The lessor has no other relevant connection to Canada, e.g., agents, employees or facilities in Canada, soliciting of Canadian business, Canadian bank accounts or servicing obligations under the lease. ...

These preferred shares were cancelled for no consideration in connection with the winding-up of the partnership and the transfer of its assets to Opco. ...

However, s. 12(l)(g) notably is not stated to be limited to circumstances in which property is sold, notwithstanding the fact that the original impetus for the provision came from a case involving the retention of a royalty in connection with a sale of property. ...

Subsection 146.2(2) provides that a “qualifying [TFSA] arrangement” must: (e) … provide that, at the direction of the holder, the issuer shall transfer all or any part of the property held in connection with the arrangement (or an amount equal to its value) to another TFSA of the holder; CRA apparently is reading into this wording a requirement that the arrangement represent transferable property. ...

15 July 2019- 12:02am CRA rules on using s. 107.4 transfers to split up ETFs Email this Content In connection with an arm’s length acquisition transaction, apparently of the business of managing exchange-listed mutual fund trusts, holders of Series D or O Units of some of such funds (the Participating Public Funds) wish to become investors in corresponding “New Funds” and thereby continue to have their investments managed by the previous managers, rather than remaining as investors in the Participating Public Funds and having their investments managed by the new managers. ...

11 October 2019- 12:06am D’Anjou – Tax Court of Canada finds that a taxpayer should have been informed by a similar loss in the Court of Quebec Email this Content In connection with finding that the taxpayer had made a misrepresentation attributable to neglect when he had treated the adjusted cost base of a property he had sold as having been increased by alleged expenses such as municipal and school taxes and financing expenses incurred during the holding of the property, Favreau J noted in particular that the same types of ACB adjustments had been denied for the disposition by the taxpayer of another parcel of vacant land by the Court of Quebec in 2008 QCCQ 7197. ...

30 July 2020- 11:24pm CRA confirms that goodwill and IP that were not on target’s tax books could be written up under s. 111(4)(e) Email this Content In connection with an acquisition of its control, Canco used a s. 111(4)(c) and(d) write-down of debt owing by a controlled foreign affiliate to designate the s. 111(4)(e) write-up of the capital cost of goodwill (Class 14.1), customer relationships (Class 14.1) and intellectual property (Class 12 – e.g., software or video copyright?). ...

They described the conduct of the assistant director in connection with their complaints as harassing, and claimed that the award constituted damages for personal injury and violation of their rights under their collective agreement, and should be treated as a personal injury award that was non-taxable under s. 81(1)(g.1). ...

CRA stated that mental infirmity was a question of fact that “does not require that the infirm individual be eligible for the disability tax credit,” and that “it must be possible to clearly demonstrate a causal connection between the mental infirmity and the dependence of the child or grandchild for support.” ...

However, there is an exclusion from the application of s. 95(2)(b) under s. 95(3)(b) where the services of FA are “performed in connection with the purchase or sale of goods.” ...