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The effect of the increased sales consideration was to reduce the related new housing rebate on some of the sales. ...
18 May 2015- 8:13pm Le Groupe Jean Coutu – Quebec Court of Appeal finds that rectification is not available to reverse an adverse tax consequence (FAPI) that the parties did not think about Email this Content The taxpayer implemented a plan, to neutralize the effect of FX fluctuations on its investment in a U.S. sub, that overlooked FAPI considerations – so that interest on a loan made by the sub back to Canada was included in the taxpayer’s income. ...
The usual single-supply doctrine applies so that, for example, a charge for ferrying a plane from another city to the embarkation point for the charter flight and various airport charges which the carrier has no choice but to incur will be part of the consideration for the passenger transportation service provided by the carrier. ...
., she rejected the proposition that the obligation of the trusts to make the special distributions was part of the consideration received by the manager. ...
CRA considers that because s. 85(1)(e) refers to the UCC of the building "immediately before" its disposition, whereas no entitlement to claim the ITC arises until the consideration for the drop-down becomes payable, the UCC for purposes of determining a permissible elected amount is $90, not $77. ...
This suggests that an exempt supply (or, presumably, a zero-rated supply) potentially can have multiple "recipients" (generally, the persons liable to pay the consideration), not all of whom satisfy the conditions for exemption. ...
The U.S. inversion rules are not expected to apply to the Trust since none of the vendors of the project LLC interests will receive Trust units in consideration for the sale nor will their continuing interests in the project LLCs have dividend, redemption or liquidation rights that are substantially similar to the rights of a holder of Trust units. ...
In a butterfly reorganization for the split-up of DC into three TCs, this circularity problem was solved by having DC transfer its properties to respective new Subcos of each TC, so that no s. 186(1)(b) Part IV tax was generated on the redemption of the prefs received by DC as consideration on this transfer. ...
12 August 2013- 10:39pm Finance is considering a domestic anti-treaty shopping rule which overrides treaty benefits Email this Content Although it has issued a "consultation" paper, so that all reasonable alternatives are open for consideration, it is quite clear that Finance is contemplating adopting a domestic treaty override provision (i.e., an amendment to or under the Income Tax Act that in specified circumstances would override otherwise-effective treaty shopping). ...
Because of this non-Canadian structure, it is possible for the subsidiary Ontario LP of the REIT to offer to acquire the shares of individual Holland Global shareholders in consideration for exchangeable units under s. 97(2), without the need to worry that it thereby would not qualify as an excluded subsidiary entity. ...