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MMV Capital – Federal Court of Appeal applies Deans Knight regarding acquiring an approximate 100% interest in a Lossco with no change of de jure control

.$86 million to the respondent, effectively in consideration for secured debt and preferred shares, thereby reducing the equity interest of the five arm’s length holders of 51% of the MMV voting common shares to less than 0.01% and also permitting the use of the respondent’s non-capital losses. ...

CRA discusses the GST/HST treatment of crowdfunding pledges

Pursuant to s. 133, “the tax applies to any advance payment or part payment of the consideration for a supply even if, at the time payment is made, property has not in fact been transferred.” ...

Black – Tax Court of Canada finds that s. 7(2) did not apply to a trust holding employer shares for employees where none of the shares were specifically allocated to specific employees

.$73 million, an estate freeze was implemented by its dominant individual shareholder, and a 15% common shareholding was issued for nominal consideration to a trust for the benefit of present and future employees. ...

CRA states sale by 2 equal shareholders of 1/3 of each’s shares to a 3rd unrelated person might not entail an acquisition of control; similarly where 1 of 4 equal shareholders is redeemed

A and B, who were the sole and equal (common) shareholders of Opco, each sold 1/3 of their shares to C, for FMV consideration. ...

Melcor Developments proposed a purchase of the partnership interest of Melcor REIT in their joint LP followed by a redemption of the REIT units

In a November 25, 2024 News Release, the REIT announced: The REIT and Developments had entered into an amended Arrangement Agreement ‎which provides for increasing the per-Unit consideration from $4.95 to $5.50; and The special unitholder meeting scheduled for November 26, 2024 was cancelled and the REIT was engaging in a new 90-day extended “go-shop” period. ...

CRA indicates that a direction letter to change how title is conveyed at closing gives rise to a real estate supply for GST/HST purposes

CRA indicated that: a direction of title change is considered to be a supply of real property or an interest in real property and that, generally, there are no exemptions that apply for newly constructed real property; the assignment by the purchaser of the agreement is normally considered to be a sale of that first purchaser's interest in the new unit which, pursuant to s. 192.1, would be deemed to be a taxable supply; and pursuant to s. 155, there would be deemed FMV consideration for such taxable supplies if the recipient in each case was not a registrant who acquired the property for consumption, use or supply exclusively in the course of commercial activities. ...

267 O'Connor – Tax Court of Canada finds that damages paid by the vendor under a failed realty sale did not generate ITCs notwithstanding some IP transferred to it

Furthermore, the appellant had not satisfied the ITC documentary requirements in that it had not demonstrated that it had the GST registration number of the supplier (Starwood) by the time its return was filed (which “alone [was] fatal to the success of the appeal” and “there [was] not sufficient evidence to determine an amount of consideration to purchase intellectual property, nor the tax paid or payable”. ...

A retroactive amendment to s. 212.1(6)(b) is intended to accommodate a pipeline transaction by a GRE with a non-resident beneficiary

15 April 2025- 11:34pm A retroactive amendment to s. 212.1(6)(b) is intended to accommodate a pipeline transaction by a GRE with a non-resident beneficiary Email this Content In a pipeline transaction where an estate with a non-resident beneficiary transfers its shares of Opco to a Newco in consideration for a note of Newco, Newco will be deemed under the current version of the s. 212.1(6)(b) conduit rule to pay to the non-resident beneficiary a dividend (subject to Part XIII tax) based on the note amount, that is generally proportionate to the relative FMV of that beneficiary's interest in the estate. ...

CRA indicates that a disproportionate allocation of DSI on a purchase spin-off can avoid the application of s. 55(2)

Opco then transferred Asset 2 to Newco in consideration for Newco shares with an ACB, PUC and FMV of $1,000. ...

CRA expands its discussion of crypto mining groups

Revised summaries of GST/HST Notice No. 324, "Mining Assets in respect of Cryptoassets" June 2025 under ETA s. 188.2(5) and s. 123(1) – consideration. ...

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