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CRA rules on a double pipeline entailing the application of s. 84.1 and s. 88(1)(d) bump

Following the death of Mother, her estate and Trust were to engage in a pipeline transaction under which: The estate and Trust transfer their Aco shares under s. 85(1) to a Newco of Trust in consideration for Newco preferred shares. ...

CRA rules on a pipeline transaction for a trust realizing a s. 104(4)(b) gain and using a non-controlled Newco

Trust 2 will transfer its Holdco common shares to Newco 2 on a s. 85(1) rollover basis for non-voting common shares, and Trust 1 will transfer its Holdco preferred shares to Newco 2 in consideration for non-voting preferred shares of Newco 2 whose PUC will equal the ACB of the transferred shares. ...

Garg Investments – Tax Court of Canada finds that the recipients of a supply were the agents named in the purchase agreement, not the beneficial purchaser

4 June 2023- 10:45pm Garg Investments – Tax Court of Canada finds that the recipients of a supply were the agents named in the purchase agreement, not the beneficial purchaser Email this Content A claimant of the new residential rental property rebate (NRRPR) is required under ETA s. 256.2(3)(a) to be the “recipient” of the supply of the property meaning, generally, that it is liable for the consideration for the supply under the purchase agreement. ...

University of New Brunswick – Tax Court of Canada finds that a post-doctoral fellow was not an employee of the University

5 June 2023- 11:13pm University of New Brunswick – Tax Court of Canada finds that a post-doctoral fellow was not an employee of the University Email this Content Bocock J indicated that whether annual awards made to a post-doctoral fellow (PDF) of the University were employee remuneration for CPP and EI purposes turned on a determination of their “dominant purpose,” namely, “whether on balance the payments were made on account of monetary assistance to enhance the PDF’s education and research skills or paid as income in consideration of various services provided by the PDF to the University.” ...

CRA confirms the application of s. 7(1.31) to the acquisition and immediate sale of RSU shares

An employee who acquired 10 common shares of the public-company employer, was also issued, for no consideration (other than services rendered), 10 restricted stock units (RSUs) of the employer under an agreement to which s. 7(1) applied. ...

CRA discusses the application of the procedural provisions for adjusting CEWS and CERS claims

Similar considerations applied to the CRHP and CERS benefits. Neal Armstrong. ...

Amex Bank – Tax Court of Canada finds that costs of Amex’ points program were inputs to its exempt credit card revenues, and did not generate ITCs

Amex submitted that the free supply rule in s. 141.01(4) applied to characterize the supply of the rewards as a taxable supply, on the basis that (i) the supply of rewards to Members was made for no consideration, and (ii) the purpose of making such supply was to facilitate the activities of the Members. ...

CRA finds that a company which negotiated agreements between credit card companies and merchants was supplying a GST/HST-exempt service

13 July 2023- 10:44pm CRA finds that a company which negotiated agreements between credit card companies and merchants was supplying a GST/HST-exempt service Email this Content “Acquirers,” who used funds from the customer’s credit card issuer to provide funds to pay merchants for their customers’ purchases, retained the Company to find merchants and negotiate agreements with them to receive such services of the Acquirer, in consideration for a fee based on the number of merchant transactions processed by the Acquirer. ...

CRA has published a memorandum on when corporations and partnerships are closely related for purposes of the ETA s. 156 election

23 July 2023- 11:37pm CRA has published a memorandum on when corporations and partnerships are closely related for purposes of the ETA s. 156 election Email this Content CRA has published a new memorandum regarding when Canadian partnerships and corporations will be considered to be closely related to each other for purposes of the ETA s. 156 (nil consideration) election. ...

LBL Holdings – Tax Court of Canada finds that “flash” sales occurring on a reserve for immediate delivery to the trucks of non-Indians were exempted from GST

As soon as LBL delivered the products to the store vicinity, and it received the cash consideration, the products were loaded onto the waiting trucks of customers, in turn, of Roberta MacNaughton. ...

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