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Centrica – UK Supreme Court finds that professional fees incurred in pursuing a subsidiary sale but before the deal was struck were capital expenditures

25 July 2024- 11:54pm Centrica – UK Supreme Court finds that professional fees incurred in pursuing a subsidiary sale but before the deal was struck were capital expenditures Email this Content The taxpayer, an intermediate UK holding company for subsidiaries in various countries, incurred fees of an accounting firm, Netherlands law firm and an investment banker in connection with the difficult process for accomplishing a share sale of, or an asset sale by, a Netherlands subsidiary (“Oxxio”). ...

CRA indicates that it has modified the application of its Indian Act Guideline 4 to reflect replacements of band councils by modern treaty governments

17 September 2024- 11:27pm CRA indicates that it has modified the application of its Indian Act Guideline 4 to reflect replacements of band councils by modern treaty governments Email this Content Guideline 4 of CRA’s Employment Income Guidelines respecting the s. 87 Indian Act exemption provides that employment income of a First Nation individual generally will be exempt where the employer is resident on a reserve and is a First Nation band which has a reserve, or a tribal council representing one or more such bands (or a related band organization as described in the Guideline) and where the duties of employment are in connection with the employer's non-commercial activities carried on exclusively for the benefit of First Nations individuals who for the most part live on reserves. ...

Delta 9 Cannabis – Alberta Court of King’s Bench determines that a reverse vesting order should not permit the target corporation to transfer out future s. 80 income tax liabilities

However, the draft RVO also provided that such excluded taxes would include any taxes related to debt forgiveness arising from or in connection with the consummation of the transaction. ...

Ehresman – Tax Court of Canada finds that cash reserves were not active business assets because they were excessive in relation to reasonably-determined risks

The case law requires a rational connection between the reasonably determined risk and the amount of the reserves. ...

St-Joseph – Quebec Court of Appeal finds that the transformation of 2 floors of commercial building to residential use did not qualify as a “termination” of commercial activity for QST purposes

It argued based on the QSTA equivalent of ETA s. 141.1(3)(a) that it had incurred the costs “in connection with the … termination of a commercial activity” of it, so that such costs were deemed to have been incurred in the course of its commercial activity, thereby entitling it to input tax refunds under the Quebec equivalent of ETA s. 169(1) – B(c). ...

Tech Mahindra – Australian Full Federal Court finds that the exception in the Australia-India Treaty for “effectively connected” royalties was not intended to exempt royalties not attributable to the source country PE from source country withholding

In any event, “’effectively connected with’ should be understood to mean having a real or actual connection with the activities carried on through the permanent establishment,” which was not the case here. ...

CRA provides expanded comments on business investment loss issues in its new Folio

Before summarizing some of the s. 40(2)(g)(ii) jurisprudence, CRA states that The burden of demonstrating a sufficient connection between the taxpayer’s loan to (or the taxpayer’s guarantee of the debts of) the debtor and the potential for income will be much higher in situations where the taxpayer is not a direct shareholder of the debtor. ...

Suncor – CRA abandons attempt to impute a hedging contract between Petro-Canada and an indirect UK subsidiary

.$2.02 billion in the 2007 income of Petro-Canada as an imputed reimbursement to Petro-Canada by its UK subsidiary of the settlement payments (and assessed a s. 247(3) penalty for failure to prepare contemporaneous documentation in connection with the imputed reimbursement.) ...

The Canadian securitization markets have largely settled on a preferred structure for each type of securitized instrument

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

The B2B rules can operate inconsistently with the intent of Canada’s treaties

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. ...

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