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CRA sort-of clarifies when tax dispute resolution fees become deductible

As for the deductibility under general (ss. 9 and 18(1)(a)) principles of professional fees incurred in connection with a voluntary disclosure, CRA states that "professional fees incurred in this context are not intended to produce income, because the VD instead permits a taxpayer to correct omissions made in the context of dealings with the CRA. ...

The safe harbour rule in the revised FAD rules for toeholds is coupled with a treacherous exclusion

This safe harbour is not available inter alia if, in connection with the investment, any person (other than the CRIC or a related person) "has in any material respect the risk of loss or opportunity for gain or profit in respect of a property that can reasonably be considered to relate to the investment. ...

CRA continues to consider that costs incurred respecting capital raises to fund an operating subsidiary are not creditable under ETA s. 186(1)

20 January 2016- 11:12pm CRA continues to consider that costs incurred respecting capital raises to fund an operating subsidiary are not creditable under ETA s. 186(1) Email this Content Memorandum 8.6, para. 11, Example 3, indicates that “HoldCo” may not claim input tax credits under ETA s. 186(1) for legal and accounting costs incurred in connection with raising money through issuing shares, even where the issuance proceeds are used to purchase additional shares in “OpCo,” all of whose property is acquired for consumption, use or supply in widget manufacturing- on the basis that the services are acquired for consumption or use in relation to the first order supply (the share issuance) and not in relation to the shares of OpCo. ...

CRA states that services are re tangible personal property for HST place-of-supply purposes if they “serve a particular need…relating to the property”

In the course of explaining a heavily redacted ruling, CRA stated: [W]hether a service is considered to be in relation to TPP depends on whether there is a direct connection between the service and the property, taking into account the objectives of the service and the particular circumstances of each case. ...

CRA references the notice clause in a services contract in determining the place-of-supply for HST purposes (and implicitly acknowledges that nutritional consulting’s purpose is maintaining health)

CRA ruled that the provision by a licensed dietician of “consultant nutrition services” to a registered charity (presumably in connection with a redacted charitable undertaking of assisting needy individuals) qualified for exemption. ...

CRA indicates that a kilometer-based minimum car allowance must be intended to compensate for actual expenses

11 September 2016- 10:21pm CRA indicates that a kilometer-based minimum car allowance must be intended to compensate for actual expenses Email this Content S. 6(1)(b)(x) deems an employee’s car allowance to be unreasonable if it “is not based solely on the number of kilometres for which the vehicle is used in connection with or in the course of the office or employment.” ...

Joint Committee Submission provides illustrations of the potential lack of integration under the new s. 55(2) rules and potential circularity issues arising on late capital dividend elections

The submission also illustrates the uncertainty regarding potential circularity arising in connection with late capital dividend elections: after the generation of a full dividend refund on a dividend paid to an individual so that the paying Holdco becomes subject to a s. 55(2) capital gain, a late s. 83(2) election is made to convert part of the dividend into a capital dividend based on s. 55(2) having generated a capital gain – but this reduces the amount of the s. 55(2) gain. ...

Barrick Gold – Tax Court of Canada finds that gains from closing out gold hedges on the sale of a mine were included in mining production profits

Paris J found that the forwards had a sufficient connection with Barrick’s Doyon mining operation, given that they were entered into in the course of that business to hedge against price fluctuations respecting the production, for the hedging gains to be income from that production. ...

The scope of the s. 212(3.6)(b) rule for converting royalties into interest is unclear

It is not clear how a logical or legal connection between interest, on the one hand, and...royalties, on the other, can exist as suggested by paragraph 212(3.6)(b). ...

S. 95(2)(a)(ii)(D) is drafted too restrictively in light of the underlying policy to extend s. 95(2)(a)(ii)(B)

The requirement for a throughout-the-year connection between FA2 and FA3 can pose difficulties for mid-year reorganizations. ...

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