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However, as the beneficiary may therefore realize a gain on the deemed disposition of her capital interest in the trust, it may be more efficient, subject to applicable foreign tax considerations, for the non-resident trust to effect an actual disposition of the property before the distribution. ...

The solution was for PWR to then transfer high basis assets to the Holdcos in consideration for preferred shares of the same class, so that the PUC of the preferred shares held by Mr. ...

In his concurring reasons, Allsop CJ stated respecting the assimilated Art. 9 rule: [W]ere CAHPL seeking to borrow for five years on an unsecured basis with no financial or operational covenants from an independent lender, in order to act rationally and commercially and conformably with the interests of the Chevron group to obtain external funding at the lowest possible cost consistently with any relevant operational considerations, it would do so with Chevron providing a parent company guarantee, if such were available. ...

Webb JA also stated that the Crown’s concern, “that the at-risk rules could be avoided entirely if the top-tier partnership (MLP) were a general partnership,” was outweighed by other considerations. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2017-07-05 7 June 2017 External T.I. 2016-0671731E5 F- Transfer of life insurance policy by dividend in kind Income Tax Act- Section 148- Subsection 148(7)- Paragraph 148(7)(a) dividend-in-kind of a life insurance policy avoids the policy’s disposition at FMV Income Tax Act- Section 52- Subsection 52(2) proceeds and cost of distributed life insurance policy determined under s. 148(7) rather than s. 52(2) 2015-01-14 10 October 2014 APFF Roundtable, 2014-0538131C6 F- revenus d'achats intégrés Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(a) full inclusion for in-app sales Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(m) no reserve for extended use by purchasers of in-apps 10 October 2014 APFF Roundtable, 2014-0538621C6 F- Disposition en contrepartie de 1$ Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(c) treatment of transfer for nominal consideration as "gift" turns on Quebec law 2015-01-07 13 November 2014 External T.I. 2014-0523911E5 F- Frais médicaux Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(a) Quebec osteopath and orthotherapist services excluded from METC 27 November 2014 External T.I. 2013-0503861E5 F- Application du paragraphe 248(16) Income Tax Act- Section 248- Subsection 248(16) ETA s. 193 ITC claim does not reduce UCC under s. 85(1)(e)(i) Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(e) ETA s. 193 ITC generated on drop-down does not reduce UCC at that time 23 September 2014 External T.I. 2013-0509021E5 F- Rajustement obligatoire Income Tax Act- Section 28- Subsection 28(1)- Paragraph 28(1)(c) qualification of non-breeding animals as inventory ...

17 July 2017- 12:56am Club Intrawest – Federal Court of Appeal splits a service in relation to a cross-border vacation home portfolio into two geographic components Email this Content Under the usual approach to applying the GST single-supply doctrine, a Canadian-resident non-share corporation, most of whose members had time share points which entitled them to book stays at Canadian, U.S. and Mexican resort condos beneficially owned by the corporation, would have been found to be receiving its annual fees from them as consideration for a single supply of a service, namely, funding the operating costs of the time share program. ...

., including both the immediate non-resident parent (Foreign SpinCo Sub) and non-resident grandparent (Foreign SpinCo) of TC in a circular exchange of consideration. ...

Those electing to receive their consideration as SmartREIT units, will have this result effected through the usual s. 132.2 mechanics. ...

A similar analysis suggests that the s. 132(2) exclusion does not undercut the exemption of a 95%-qualified partnership under draft s. 132(6) from the qualifying consideration rule in ETA s. 218.01. ...

In order for Sprott to effectively purchase the Spicer management business and for CFCL to be converted into a mutual fund trust, it is proposed that under an Alberta Plan of Arrangement, the common shares will be sold to Sprott for cash consideration reflecting the value of their voting rights (there is no coattail), the shares of a “New Administrator” will be sold to Sprott for $85M in cash and 7M Sprott shares plus an earnout, and CFCL will be merged under s. 132.2 into a trust newly-formed by Sprott (Sprott Physical Gold and Silver Trust). ...