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30 August 2013- 12:33am CRA respects a “gift” of shares to a public foundation occurring in a technology-commercialization context Email this Content S. 149.1(3)(c), which effectively prohibits a public foundation from acquiring control of any corporation, is ameliorated by s. 149.1(12)(a), which indicates that there is no such acquisition of control where the foundation has not acquired the shares of the corporation for consideration. ...

The electing NEM shareholders must provide completed s. 85 election forms to Exchangeco within 90 days of the effective date of the plan of arrangement, and full rollover treatment may not be available to them depending on the portion of the consideration which they are required to receive in cash. ...

Email this Content In a net asset split-up butterfly, the assets to be transferred to the transferee corporation were first rolled down to a Newco by the distributing corporation in consideration for shares and the assumption of liabilities, with Newco then being transferred (through several steps) to the transferee corporation.  ...

CRA characterized the FA2 shares received by Canco on the merger as consideration for Canco's cancelled shares of FA1, so that s. 87(4)(a) deemed Canco to have disposed of its shares of FA1 for their adjusted cost base, rather than draft para. ...

Treasury attorney stated yesterday that the U S. is willing to accept Canada's exclusion of most personal investment companies and trusts from consideration as financial institutions- so that they will not be required to report U.S. ...

21 January 2014- 10:39am Eclipse Film – Explanatory Notes can be more valuable than white papers Email this Content In reviewing Explanatory Notes which indicated that the provision under consideration was not intended to change the law, the UK Upper Tribunal quoted approvingly obiter comments in the House of Lords to the effect that Explanatory Notes may be more valuable than "pre-parliamentary aids" such as white papers, as they have a closer connection to the actual legislation. ...

. – Tax Court of Canada rejects plan for generating ITCs for legal fees Email this Content A group of four corporations and their ultimate individual shareholder were unsuccessful in generating input tax credits for GST/HST on legal fees by assigning the rights to the proceeds of the actions to a fifth group company in consideration for that company assuming obligations for the legal fees. ...

7 November 2016- 12:11am CRA references shareholder’s benefit on gratuitous transfer of critical illness policy by corporation to its shareholder Email this Content CRA noted that the transfer of a critical illness insurance policy by a corporation to its shareholder would not give rise to a capital gain to the corporation, but appeared to consider that if the transfer was made for no consideration, there would be a taxable shareholder benefit conferred on the shareholder equal to the policy’s fair market value. ...

8 May 2017- 11:39pm CRA rules that the Alberta carbon tax is subject to GST Email this Content CRA has ruled that a natural gas distributor is required to include the Alberta carbon-tax levy (which it is required to collect from its customers) in the value of the consideration for such natural gas supplies for GST purposes – so that effectively the Canadian government is imposing GST on the Alberta carbon tax. ...

CRA was able to deal only with some of the issues, which were subsequently discussed at the 2017 Annual CTF Roundtable, and the Joint Committee has now asked for Finance’s consideration of these issues. ...