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Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.-- summary under Paragraph 18(6)(d) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(6)- Paragraph 18(6)(d) Simplified overview of rule (p. 10:13) [A] safe harbour exists when the intermediary debt represents less than 25 percent of the Canadian debt, which ensures that the back-to-back loan rules do not apply if the Canadian debt is funded by the intermediary mainly from sources other than a non-resident connected with the Canadian resident. ...

Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper-- summary under Paragraph 80(2)(h) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(2)- Paragraph 80(2)(h) Changes that reduce debt FMV (p. 13:7) [C]hanges to certain terms of a debt, such as interest rates and payment schedules, should not lead to a forgiven amount in and of themselves, provided that the principal amount of the debt is not altered, even though such changes may reduce the market value of the debt…. ...

Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.-- summary under Paragraph 13(27)(b) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(27)- Paragraph 13(27)(b) Use of rolling-start rule in s. 13(27)(b) to accelerate CCA (p. 10:20) [G]iven the long duration of major construction projects, the rolling-start rule described above is frequently used to accelerate CCA claims to a time before the asset would otherwise be available for use. ...

Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.-- summary under Paragraph 20(1)(e.1) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e.1) Treatment of fees as s. 20(1)(e.1) deductions (pp. 10:22-3) It is unlikely that the initial professional fees related to the financing of a major construction project would be deductible under paragraph 20(l)(e.l). ...

Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.-- summary under Tax Shelter Summary Under Tax Topics- Income Tax Act- Section 237.1- Subsection 237.1(1)- Tax Shelter Sale of interest in LNG project potentially a tax shelter (p. 10:25) [A] proponent of a major construction project seeks to sell all or a portion of its interest in the project to a new investor. ...

Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Non-deductibility of post-CCAA-stay interest (p. 13:29) [C]reditors are only prevented under the CCAA stay from enforcing the debtor company's obligations. ...

Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper-- summary under Paragraph 18(1)(e) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) CCAA Stay does not generate a s. 18(1)(e) contingency (p. 13:32) [W]hile a stay under the CCAA stays proceedings with respect to damage claims, such a stay does not, in and of itself, render any liability for such damages contingent for the purposes of paragraph 18(l)(e). ...

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 Paragraph 128.1(1)(d) Summary Under Tax Topics- Income Tax Act- Section 128.1- Subsection 128.1(1)- Paragraph 128.1(1)(d) General effect of the s. 128.1(1)(d)(iii) limitation (p. 32:13) [T]he emigrating individual may elect to expand the application of the deemed disposition provisions … to … Canadian real estate, Canadian resource property, Canadian timber resource property and certain property used to carry on a business in Canada.... ...

Michael Dolson, "Trust Residence After Garron: Provincial Considerations", Canadian Tax Journal, (2014) 62:3, 671-99.-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) Application of corporate central management and control test (pp. 694-5) [O]nce the elements of control in respect of the trust property have been ascertained, it is the place from which that control is exercised that is relevant, and not the day-to-day location of the "controller. ...

Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.-- summary under Taxable Services Summary Under Tax Topics- Other Legislation/Constitution- British Columbia- Provincial Sales Tax Act- Section 1- Taxable Services Exemption for services to install TPP that will become real property (p. 10:31) Taxable services include any service provided to install, assemble, repair, adjust, restore, recondition, or maintain any TPP. ...