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Fio – Tax Court of Canada confirms that information obtained on discovery cannot be used by CRA to make further reassessments

" However, rather than vacating the further reassessments, he ordered that the discovered documents could not be used in connection with the further reassessments (subject to the Crown getting permission, which would only be granted in "exceptional" circumstances), and also awarded $25,000 in costs against the Crown. ...

Calloway is eliminating its 2-tier trust structure in order to convert for accounting reasons to a closed-end fund

In connection with ensuring that exchangeable LP units held in the subsidiary LPs will not be treated as debt for accounting purposes, it will convert to a closed-end fund pursuant to a ruling it obtained on August 13, 2013. ...

Surrey City Centre Mall - Tax Court decision suggests that intercompany debt reductions following a settlement can give rise to double GST taxation

This case illustrates that care should be taken if any intercompany or other debts are settled in connection with a contractual settlement. ...

CRA finds that a non-resident airline with no Canadian PE is required to withhold from the remuneration of its non-resident employees unless a Reg. 102 waiver is obtained

This is starting to engage the Exida.com principle ("the obligation to file could only extend to those that had some connection with Canada,") and the presumption against extra-territoriality (Society of Composers). ...

CRA applies upper tier debt on a pro rata basis for purposes of applying the 10% limitation rule in s. 55(3.1)(b)(i)(A)(II) respecting a cross-border butterfly

CRA has ruled that if Foreign Spinco borrows money from a third party following the butterfly reorganization and before the spin-off, such debt will be considered to reduce the fair market value of the assets of the holding companies for Canco, and the other assets of Foreign Spinco, on a pro rata basis for these purposes, even if there is no logical connection between the use of that borrowing and the shares of Canco. ...

CRA rules that passive interest income qualifies under the active trade or business test in Art. XXIX A, para. 3 of the Canada-U.S. Treaty

., the income in question is derived in connection with, or is incidental to, that trade or business, and the U.S. active trade or business in the U.S. is substantial relative to the activity in Canada that gave rise to the income in question. ...

CRA accepts that dividends paid to a U.S. parent in Chapter 11 are beneficially owned by it rather than the creditors

XXIX-A is applicable, as the dividends will be derived by the parent "in connection with an active trade or business carried on in the United States that is substantial in relation to the activity in Canada that gave rise to the income. ...

Finance narrows the scope of the back-to-back loan rules

The scope of an intermediary debt has been narrowed in the 20 October 2014 version of the draft legislation from the 29 August 2014 version: A strong causal connection now is required (through use of a "because" linkage (see Hoefele, Williams), except in the obvious case of limited recourse intermediary debt) between the intermediary debt and the Canco debt Reference is made to the Canco debt having become owing to the intermediary "because" of a security interest or other "specified right" of the intermediary, which again is more stringent than the August 29 version Furthermore, the holder of security may now pledge the secured property to secure the repayment of other debts which are part of the same package – and default does not result in a specified right provided that the intermediary must use any sale proceeds from the secured property to repay the Canco debt (or the related debts) However, a safe harbour, for situations where intermediary debts represent less than 25% of qualifying categories of loans owing by and related secured property of Canco, remains quite narrow. ...

CRA finds that a U.S. LLC’s intra-group lending business can qualify its C-Corp. member, under the Treaty active trade or business test, for the 0% Treaty-reduced rate on an LLC loan to a Canadian affiliate

Treaty indicates that a U.S. resident which is not a qualifying person nonetheless will be eligible for Treaty benefits with respect to income derived from Canada in connection with a substantial business (other than, in the case of a non-financial institution, a business of making or managing investments) actively conducted in the U.S., including such income derived by it "through" another U.S. resident. ...

CIBC - Federal Court of Appeal severely restricts the doctrine that expenses of "egregious or repulsive" conduct are non-deductible

" She didn't give examples, but something like expenses of a call girl or hit man would not have any acceptable connection to a legitimate business. ...

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