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Bundle Date Translated severed letter Summaries under Summary descriptor 2014-01-15 15 October 2013 Internal T.I. 2013-0491951I7 F- Travaux en cours au moment du retrait d'un associé Income Tax Act- Section 34 no new s. 34 election required if s. 98(6) or (5) applies/election can be made in income reconciliation 12 November 2013 Internal T.I. 2013-0497611I7 F- Feuillet T1204 Income Tax Regulations- Regulation 237- Subsection 237(2) T1204 disclosure applicable only where contract with federal supplier and includes travel reimbursements as “services” consideration 11 October 2013 APFF Roundtable, 2013-0496511C6 F- Actions prescrites Income Tax Regulations- Regulation 6205- Subsection 6205(2) simultaneous freezes by arm's length shareholders for their respective families to not qualify because the respective trusts/beneficiaries are not NAL with each freezor 11 October 2013 APFF Roundtable, 2013-0495691C6 F- Clause restrictive Income Tax Act- Section 56.4- Subsection 56.4(1)- Eligible Interest must be one, rather than more than one, underlying corp Income Tax Act- Section 56.4- Subsection 56.4(3)- Paragraph 56.4(3)(c) non-solicitation clause/divergence of covenanter and seller Income Tax Act- Section 56.4- Subsection 56.4(7)- Paragraph 56.4(7)(b) non-solicitation clause could be treated as part of a non-compete Income Tax Act- Section 56.4- Subsection 56.4(7)- Paragraph 56.4(7)(f) maintenance of Holdco fmv/divergence of seller and covenanter 2014-01-08 10 December 2013 External T.I. 2013-0480771E5 F- Winding-Up of a Corporation Income Tax Act- Section 88- Subsection 88(2) deemed year end under s. 88(2)(a)(iv) is only for surplus computation purposes ...

Accordingly, the Partnership first transfers its Opco shares to MFC under s. 85(2) in consideration for most of the shares of MFC (so that Opco then can be vertically amalgamated with MFC). ...

The solution was for PWR to then transfer high basis assets to the Holdcos in consideration for preferred shares of the same class, so that the PUC of the preferred shares held by Mr. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2013-07-24 30 April 2013 External T.I. 2013-0479451E5 F- Paiement forfaitaire rétroactif admissible Income Tax Act- 101-110- Section 110.2- Specifed Portion lump sum received respecting wrongful termination of disability payments that should have been paid in prior years was eligible Income Tax Regulations- Regulation 200- Subsection 200(1) lump sum received respecting wrongful termination of disability payments was reportable on T4A 14 May 2013 External T.I. 2013-0484971E5 F- PUGE- décès du conjoint Income Tax Act- Section 56- Subsection 56(6) deceased had spouse at the end of her terminal year Income Tax Act- Section 56- Subsection 56(9.1) deceased’s income did not include income on her rights and things return 14 May 2013 External T.I. 2013-0480561E5 F- Méthode de recouvrement du coût Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) calculation uncertainty not resolved within 5years/earnout tied instead to properties of sub 23 May 2013 External T.I. 2012-0472101E5 F- Emphytéose- disposition de terrain Income Tax Act- Section 54- Proceeds of Disposition building erected on land was the consideration for the emphyteutic grant 3 May 2013 External T.I. 2013-0480991E5 F- Frais d'examen et de préparation à un examen Income Tax Act- Section 118.5- Subsection 118.5(1)- Paragraph 118.5(1)(d) fees for U.S. exam were necessary for actuarial accreditation in Canada 17 April 2013 External T.I. 2013-0475301E5 F- Résidence principale- changement d'usage partiel Income Tax Act- Section 45- Subsection 45(1)- Paragraph 45(1)(c) ancillary income-producing use requirement may not be met where house basement is rented out ...

Given the broad nature of these provisions, where a private foundation is a beneficiary under an alter-ego trust, consideration must be given to subsections 188.1(3.3) to (3.5) for the purposes of determining the private foundation’s excess corporate holdings percentage and divestment obligation percentage for a taxation year. ...

. – Court of Appeal of England and Wales finds that the ability of successor to apply predecessor losses to income from the same trade did not extend to profits from an enlarged trade Email this Content A British taxpayer (Leekes) carrying on a retail trade through four stores acquired, for nominal consideration, all the shares of another company (Coles) carrying on a similar retail trade through three stores, and then effectively wound-up Coles so as to carry on the operations of the three former Coles’ stores directly. ...

19 September 2018- 11:48pm CRA finds that SLFI tax must be remitted irrespective of a failure of a SLFI supplier to charge the tax going into the SAM formula Email this Content A Canadian financial institution makes a taxable supply of services to an unrelated Canadian selected listed financial institution (SLFI) for cash consideration, but erroneously fails to invoice and collect any GST/HST thereon. ...

Where at the same time as an estate freeze an employee received common shares of the Freezeco (an arm’s length employer) for nominal consideration and immediately contributed the shares to her TFSA, there would be an advantage equalling the shares’ subsequent appreciation (as well as any dividends received thereon). ...

Finance Trust will transfer all it notes to the REIT for no consideration, the REIT will purchase all the Finance Trust units for what now is their nominal value and Finance Trust will be terminated through its redemption of its units. ...

Accordingly, Crombie LP first transferred its CDL shares to MFC under s. 85(2) in consideration for most of the shares of MFC (so that CDL could then be vertically amalgamated with MFC to form Amalco). ...