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Colitto) for nominal consideration. In 2016, CRA assessed Ms. Colitto on the basis that Mr. ...

Given that the core premise-- that absent tax considerations, the investment in the FA would have been made by the discretionary beneficiary is almost certainly false-- s. 212.3(26)(c) should be scrapped. ...

Before concluding that “the taxpayer has established that the prices that CMPL was paid by GIAG for the copper concentrate it supplied to GIAG under the … Agreement were within an arm’s length range” (and before quoting with approval the statement in Cameco that “The traditional transfer pricing rules must not be used to recast the arrangements actually made among the participants,”) Davies J stated: As made clear in Chevron, the task of ascertaining the consideration that might reasonably be expected would have been paid to CMPL for the copper concentrate that it sold to GIAG is not to be undertaken upon the hypothesis that CMPL was not a member of the Glencore Group. … [T]he relevant mine producer for the purposes of the [arm’s length] hypothetical agreement is a mine producer with all the characteristics of CMPL, which include … that it had no need for a logistics or marketing division because it sold the whole of its production for the life of the mine to a buyer with GIAG’s characteristics, namely a trader with a substantial marketing team which purchased the whole of the mine’s production for the life of the mine. ...

7 October 2019- 11:44pm Income tax issues for pension real estate corporations can arise when investing in LPs or real estate joint ventures Email this Content Observations on income tax considerations relevant to s. 149(1)(o.2) corporations include: A s. 149(1)(o.2)(iii) corporation is precluded from issuing “bonds, notes, debentures or similar obligations.” ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2020-01-08 12 November 2019 External T.I. 2019-0822161E5 F- T5008 Statement of Securities Transactions Income Tax Regulations- Regulation 230- Subsection 230(1)- Sale a contribution of shares to a TFSA is not a “sale” for Reg. 230 purposes Income Tax Regulations- Regulation 230- Subsection 230(2) transfer of listed shares from taxable brokerage account to individual’s TFSA did not generate T5008 reporting requirement 2011-03-11 8 October 2010 Roundtable, 2010-0373621C6 F- Utilisation abusive des fiducies familiales Income Tax Act- Section 245- Subsection 245(4) examples of the abusive use of family trusts engaging GAAR 11 February 2011 External T.I. 2010-0386651E5 F- Admissibilité- Frais médicaux Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(o) pathology expenses paid to physician would qualify Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(a) preliminary report of genetic counsellor would not qualify 8 October 2010 APFF Roundtable, 2010-0373301C6 F- Classes of shares with identical characteristics Income Tax Act- Section 89- Subsection 89(1)- Paid-Up Capital identical but separate QBCA classes would have separate PUC Income Tax Act- Section 47- Subsection 47(1) shares of identical but separate QBCA classes are identical properties unless their PUC rights differ 8 October 2010 APFF Roundtable Q. 11, 2010-0373281C6 F- Redemption of shares and eligible dividend Income Tax Act- Section 89- Subsection 89(14) specific dollar amount required for regular dividends, but not for deemed dividend 2011-03-04 3 February 2011 External T.I. 2010-0389601E5 F- Allocation de transport Income Tax Act- Section 3- Business Source/Reasonable Expectation of Profit allowance from school in “consideration” for arranging child transport was non-taxable ...

III, s. 13 exempts: a supply of a meal to a student enrolled at a university or public college where the meal is provided under a plan that is for a period of not less than one month and under which the student purchases from the supplier for a single consideration only the right to receive at a restaurant or cafeteria at the university or college not less than 10 meals weekly throughout the period. ...

More specifically: Aco establishes a new sister to Bco (Newco) to which Aco does an s. 85(1) drop-down of preferred shares of Bco having a fair market value equaling that of the trademarks; Bco spins-off the trademarks to Newco on a partial rollover basis in consideration for prefs of Newco, thereby using Bco’s net capital losses to effect a ½ step-up of the UCC of the trademarks under s. 13(7)(e)(ii) – and with Newco licensing the trademarks back to Bco for royalties; The prefs in 1 and 2 above are cross-redeemed (with reliance on the s. 55(3)(a) exception to s. 55(2)); Newco is wound-up under s. 88(1); Aco does an s. 85(1) drop-down of the trademarks back to Bco, but choosing an elected amount so as to uses up its net capital losses and to effect a further ½ step-up of the trademarks' UCC under s. 13(7)(e)(ii). ...

17 March 2020- 11:38pm Denso – Federal Court finds that CRA had reasonably not accepted a late ETA s. 156 election where the companies had carelessly not found out about the new filing requirement Email this Content S. 156(4)(b)(ii) permits the Minister to allow a late-filed ETA s. 156 nil consideration election. ...

A suggestion: Assume that the LIT transfers its shares of Opco for Holdco shares alone (that is, without receiving any non-share consideration). ...

These considerations were reinforced by the purposes of s. 227.1, which had been judicially stated to be “to strengthen the Crown’s ability to enforce the statutory obligation imposed on corporations to remit source deductions,” whereas the Tax Court interpretation “render[ed] this purpose nugatory and pointless.” ...