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Choice Properties is proposing to acquire CREIT with a choice of cash, or Choice units issued on a s. 132.2 merger

1 April 2018- 11:29pm Choice Properties is proposing to acquire CREIT with a choice of cash, or Choice units issued on a s. 132.2 merger Email this Content The proposed acquisition of CREIT (which is a closed-end REIT holding most of its properties directly or through subsidiary LPs) by Choice Properties- which is an Ontario open-end REIT holding a partial interest in a property-holding LP (Choice Properties LP)- would occur for aggregate consideration of approximately $1.7B in cash and Choice Properties units valued at around $2.1B. ...

626468 New Brunswick – Tax Court of Canada finds that safe income was reduced by corporate income taxes that would be computed on that income

1 June 2018- 12:27am 626468 New Brunswick – Tax Court of Canada finds that safe income was reduced by corporate income taxes that would be computed on that income Email this Content An individual rolled his apartment building into a Newco in consideration for a mortgage assumption and shares with nominal paid-up capital, and then rolled those shares into a new Holdco. ...

Toronto-Dominion Bank – Federal Court finds that the deemed trust for unremitted GST defeated the mortgagee’s priority on a voluntary sale of the mortgaged home

Similar considerations arise under other statutes, e.g., ITA s. 227(4.1). ...

CRA finds that the distribution to a non-resident parent of assets of a subsidiary that had SERP obligations and the assumption of such obligations did not create an RCA

With the consent of the Pensioners, the non-resident “Parent” (which actually appears to be an Opco grandparent) assumes these “SERP Obligations” for no consideration. ...

CRA, changing its mind, concludes that two Canadian sisters can be closely related for GST/HST purposes through multiple stacked NR corporations above them

As a result, it concluded that sufficient stacking of corporations can result in an inability of all group members to make the ETA s. 156 nil consideration election. ...

CRA rules on a combined pipeline and split-up butterfly

DC then transferred its marketable securities to three transferee corporations (TCs) for the three beneficiaries in consideration for “butterfly shares” – but with DC holding onto the notes that it received on the immediate redemption of the butterfly shares for a redacted period of time. ...

CRA indicates that the s. 148(8) rollover can apply on a policy transfer to a substituted child

6 July 2018- 1:44am CRA indicates that the s. 148(8) rollover can apply on a policy transfer to a substituted child Email this Content S. 148(8) provides that, if an interest of a policyholder in a life insurance policy is transferred to the policyholder’s child for no consideration and a child of the policyholder is the person whose life is insured, the interest is deemed to have been disposed of on a rollover basis (based on the adjusted cost basis of the interest). ...

Minto Apartment REIT is using a Class B exchangeable and Class C preferred unit structure

This is being accomplished first by Minto Properties transferring the portfolio (appraised at $1.179 billion) to a newly-formed wholly-owned LP in consideration for cash, the assumption of a portion of the related secured debt, the issuance of two promissory notes and a partnership interest that then will be converted into “common” Class A units, exchangeable Class B units and “preferred” Class C units, with Minto Properties then selling its Class A units to the REIT for a note that is repaid out of the IPO proceeds. ...

Complexities can arise in determining the contribution of foreign affiliates to safe income on hand

Summary of Jim Samuel, "Interaction of the Foreign Affiliate Surplus and Safe-Income Regimes: Selected Anomalies, Issues, and Planning Considerations", Canadian Tax Journal, (2018) 66:2, 269-307 under s. 55(5)(d). ...

Devon – Tax Court of Canada finds that payments made to target’s employees for surrendering their options on target’s acquisition were mostly deductible by it

Among other considerations, he determined that the surrender payments were made for the purpose of gaining or producing income from the acquired companies’ business given that under this test “it will suffice if the income-gaining purpose is [only] one of the purposes of the outlay or expense” and that, similarly to Imperial Tobacco, the surrender payments had “an employer-compensation-related purpose.” ...

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