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LBL Holdings – Tax Court of Canada finds that “flash” sales occurring on a reserve for immediate delivery to the trucks of non-Indians were exempted from GST

As soon as LBL delivered the products to the store vicinity, and it received the cash consideration, the products were loaded onto the waiting trucks of customers, in turn, of Roberta MacNaughton. ...

There is a concern that redeeming the preferred shares of a related individual at the commencement of a butterfly reorganization would oust the butterfly exception

There is greater certainty if Dad instead transfers his DC preferred shares to each of the TCs in consideration for voting shares of the TCs, with the TCs then redeeming those preferred shares. ...

Northbridge Commercial Insurance – Federal Court of Appeal finds that zero-rating for fleet insurance could be based on the relative expected claims experience for US accidents

The Tax Court had not considered the evidence relating to this point, and the matter was referred back to it for such consideration. ...

Sommets du Mont-Tremblant – Court of Quebec finds that an in-kind damages payment should be treated the same as a sale of the transferred property

In the settlement, it agreed that, in consideration for the $400,000 referred to above, it would transfer a particular property (not covered by the option) to Solstice. ...

9154 – Court of Quebec finds that the ARQ contravened its role by assessing a taxpayer for QST on a property transfer while continuing to collect QST as if the taxpayer was still owner

6 February 2024- 11:30pm 9154 – Court of Quebec finds that the ARQ contravened its role by assessing a taxpayer for QST on a property transfer while continuing to collect QST as if the taxpayer was still owner Email this Content The ARQ assessed the appellant (9154-6093) for its failure to collect and remit QST on its transfer of a condo unit to the couple who were its shareholders for stated consideration. ...

CRA states that it will continue to issue post-mortem pipeline rulings following the GAAR amendments, but will not rule on surplus stripping by individuals

However, the Directorate noted the example provided in the Explanatory Notes of a surplus-stripping transaction of Jane in which she realized a capital gain on a dirty s. 85 exchange of her Opco shares, transferred her stepped-up Opco shares to another corporation controlled by her (Buyco) in consideration for a Buyco note, with Opco then dividending its earnings to Buyco for application in repaying the note. ...

CRA indicates that if an agreement for the supply by a resident of IPP (e.g., copyright) has no stated restrictions on where the IPP may be used, the supply is wholly in Canada

., copyright) has no stated restrictions on where the IPP may be used, the supply is wholly in Canada Email this Content A Canadian resident agrees with a non-resident (ACo) that, in consideration for royalty payments, the resident will upload books and designs created by him or her to the ACo platform, which ACo customers can then choose to receive in electronic form or print off or (in the case of the designs) have them printed on products acquired by them from ACo. ...

CRA rules on a pipeline transfer by an inter vivos trust of preferred shares (stepped-up under s. 104(4)(b)(ii)) for notes

CRA ruled on pipeline transactions in which the trust would transfer its remaining Holdco 2 preferred shares to another existing family holding company (Holdco 1) in consideration for Notes 1, 2 and 3 of Holdco 1, and then distribute (apparently, immediately) Notes 2 and 3 pursuant to s. 107(2) to Child 1 and 2, respectively and receive repayment of Note 1 to fund its capital gains tax. ...

CRA provides an unredacted schedule for repayment of a pipeline note

29 November 2024- 12:00am CRA provides an unredacted schedule for repayment of a pipeline note Email this Content CRA ruled on a pipeline transaction for a testamentary spousal trust, following the death of the spouse, under which it distributed its common shares of the portfolio company to its two individual residuary beneficiaries under s. 107(2) and sold its preferred shares of the company to a Newco set up by those beneficiaries in consideration mostly for a note, and they transferred their common shares of the portfolio company to Newco on a s. 85 rollover basis. ...

CRA maintains that safe income of pref shares issued on a s. 85 share-for-share exchange matches the exchanged shares’ safe income, with subsequent dividend increases

" (Full paper released on 22 December 2023) which stated that, where a shareholder acquires preferred shares as consideration for the transfer of property on a tax deferred basis, the accrued gain on the property, when subsequently realized by the corporation, would be viewed as contributing to the gain on the preferred shares, and accordingly would be included in the preferred shares’ safe income. ...

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