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CRA rules on a butterfly split-up that is integrated with a prior pipeline transaction

As a result of that pipeline transaction, the estate ended up holding both preferred shares and a note of the corporation (the distributing corporation or DC) resulting from the amalgamation of the Newco used in connection with the pipeline transaction and Holdco. ...

We have translated 6 more CRA interpretations

Bundle Date Translated severed letter Summaries under Summary descriptor 2001-04-27 10 April 2001 External T.I. 2001-0078035 F- RAP PERSONNE DIVROCEE Income Tax Act- Section 146.01- Subsection 146.01(1)- Regular Eligible Amount- Paragraph (f) divorced individual was eligible notwithstanding ownership during their marriage of home by ex-spouse 12 April 2001 External T.I. 2000-0050655 F- ASSURANCE MUTILATION/INVALIDITE Income Tax Act- Section 148- Subsection 148(9)- Disposition- Paragraph (h) disability benefits under a policy providing life and accidental death and dismemberment insurance could be non-taxable Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account personal injury amounts received pursuant to life insurance policy not added to CDA 23 March 2001 Internal T.I. 2000-0056097 F- Roulement interne Income Tax Act- Section 84- Subsection 84(1) s. 84(1) deemed dividend where individual’s low-PUC common shares are exchanged with the corporation for high-PUC preferred shares and there is an s. 85(1) agreed amount at FMV 17 April 2001 External T.I. 2000-0056455 F- AVANTAGE IMPOSABLE-EMPLOYE Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) the distribution of employer shares to employees as beneficiaries of a discretionary trust is a s. 6(1)(a) benefit if it has the slightest connection to their employment 2 February 2001 Internal T.I. 2000-0058127 F- Convention d'émission d'actions follow-up in 2001-007939 F Income Tax Act- Section 7- Subsection 7(2) s. 7(2) could apply if shares were held by the employer for later acquisition by the employee 19 April 2001 Internal T.I. 2001-0069067 F- PENSION ALIMENTAIRE ACCORD ECRIT Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount submitted documents were not a written agreement ...

Raiche – Court of Quebec finds that a suspended Quebec police officer had not severed his Quebec ties when he started living (except when in Quebec) with his son in Ontario

2 February 2025- 11:42pm Raiche – Court of Quebec finds that a suspended Quebec police officer had not severed his Quebec ties when he started living (except when in Quebec) with his son in Ontario Email this Content Raiche started living with one of his two sons in Petawawa Ontario when, in November 2015, he was suspended from his employment with the Quebec police force in connection with a criminal investigation of him. ...

The Joint Committee recommends that the s. 116 certificate system be administered in a less cumbersome and aggravating manner

That CRA (departing from 2019-0798861C6) confirm that the excluded disposition rule in s. 150(5)(b) will be satisfied where all Part I tax owing in respect of the TCP disposition is paid in connection with the issuance of a s. 116 certificate (so that no Canadian return filings- or filings in relation to a limited partnership- is required). ...

CRA finds that a vendor’s disclosing on its invoices the amount of meal allowances paid to its sales people transferred the 50% s. 67.1 denial onto the purchasers

The taxpayer, which sold goods for a fixed price payable in instalments, paid reasonable meal allowances to its employees for their travel in connection with the sales (e.g., installations). ...

CRA publishes a new GST/HST Memorandum on private instruction and tutoring

. … In order for the exemption to apply, it must be evident that there is some direct connection between the supply of the service of tutoring or instructing in question and the course approved for credit by, or the curriculum designated by, a school authority. ...

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. ...

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