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Gordon Zittlau, "Corporate Reorganizations Involving Taxable Canadian Property – Foreign Merger Considerations", International Tax Planning (Federated Press), Vol. ...

Michel Ranger, Rhonda Rudick, "Federal and Provincial Tax Considerations Relating to Non-Resident Investment in Canadian Real Estate", 2019 Conference Report (Canadian Tax Foundation), 32:1 – 39-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Taxable Canadian Property- Paragraph (c) ARQ position that shares with no connection to Quebec can be taxable Quebec property (pp. 32:20-21) [I]n certain circumstances shares of a corporation (whether Canadian or foreign) could constitute TQP even when the corporation in question has no assets or property in, or any other connection to, the province of Quebec. ...

Janette Pantry, Carrie Smit, "Tax Considerations in Restructuring under the Companies’ Creditors Arrangement Act", draft 2020 CTF Annual Conference paper-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) Interest stops rule applicable to unsecured debt (pp. 21-23) Under the interest stops rule, interest on unsecured provable claims stops accruing at the commencement of relevant proceedings, given that all unsecured creditors should generally receive equal treatment, so that the assets should be distributed amongst the unsecured creditors pro rata to their claims existing at the time of the insolvency. ...

Gordon Zittlau, "Corporate Reorganizations Involving Taxable Canadian Property – Foreign Merger Considerations", International Tax Planning (Federated Press), Vol. ...

Manon Thivierge, "Income Tax Due-Diligence Considerations in Mergers and Acquisitions", 2015 Conference Report (Canadian Tax Foundation), 18:1-29-- summary under Subsection 89(11) Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(11) Deemed year-end on ceasing to be a CCPC (p. 18:16) [U]nder subsection 249(3.1), when a corporation either becomes or ceases to be a CCPC (otherwise than by way of an acquisition of control to which subsection 249(4) applies), it is deemed to have a taxation year-end immediately before the time that it becomes or ceases to be a CCPC. ...

Brian Kearl, Carl Deeprose, "Leaving Canada's New High Tax Rate Regime: Considerations, Tips and Traps", 2016 Conference Report (Canadian Tax Foundation),32:1-24-- summary under Subparagraph (c)(ii) Summary Under Tax Topics- Income Tax Act- Section 210- Designated Income- Paragraph (c)- Subparagraph (c)(ii) Conversion of trusts deemed disposition income into “designated income” for purposes of Part XII.2 (pp. 32:16-17) If an emigrating individual's interest in a personal trust is exempted from the departure tax and is not subject to part XII.2 tax as discussed below, taxation of any inherent gains in the trust property may be deferred until its actual disposition and the gains may be subject to part XIII withholding tax rather than part I income tax. … Generally, paragraph 104(4)(a.3) triggers a deemed disposition of the property held by a personal trust if a taxpayer transfers property to the trust and it is reasonable to conclude that the property was transferred in anticipation that the taxpayer would subsequently cease to reside in Canada, and then the taxpayer did subsequently cease to reside in Canada. ...

Michel Ranger, Rhonda Rudick, "Federal and Provincial Tax Considerations Relating to Non-Resident Investment in Canadian Real Estate", 2019 Conference Report (Canadian Tax Foundation), 32:1 – 39-- summary under Regulation 805 Summary Under Tax Topics- Income Tax Regulations- Regulation 805 Factual distinction between business and property income for corporation (p. 32:4) In the case of a corporation whose sole activity is the ownership of such property, there is a presumption that a corporation is formed for the purpose of carrying on business; accordingly, where the corporation has only one activity or investment—regardless of its nature—the corporation may be held to be carrying on a business in respect of such single activity or investment. ...

Michel Ranger, Rhonda Rudick, "Federal and Provincial Tax Considerations Relating to Non-Resident Investment in Canadian Real Estate", 2019 Conference Report (Canadian Tax Foundation), 32:1 – 39-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Taxable Canadian Property- Paragraph (a) Quebec taxation of income from specified immovable property [N[on-resident inter vivos trusts that own immovable property in Quebec and that earn rental income from that property (that is, passive rental income that does not constitute business income earned through an establishment in Quebec) are also subject to provincial tax in Quebec. ...

Michael Dolson, "Trust Residence After Garron: Provincial Considerations", Canadian Tax Journal, (2014) 62:3, 671-99.-- summary under Subsection 2601(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 2601- Subsection 2601(1) Structuring so that decisions are made in a different jurisdiction (pp. 692-3) Once the identity of the person who has central management and control is ascertained, the residence of the trust can be resolved by identifying the place where J that person exercises the powers constituting central management and control. ...

Michel Ranger, Rhonda Rudick, "Federal and Provincial Tax Considerations Relating to Non-Resident Investment in Canadian Real Estate", 2019 Conference Report (Canadian Tax Foundation), 32:1 – 39-- summary under Subsection 216(1) Summary Under Tax Topics- Income Tax Act- Section 216- Subsection 216(1) Tax computation where s. 216(1) election (p. 32-6) Where a section 216 election is made, income is computed as it is (in the manner set out above) to determine taxable income for business property, with one exception: losses of other years may not be applied in determining the taxable income. ...