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Leonard – Tax Court of Canada finds that on a foreclosure, the taxpayer disposed of his mortgage, even though the debt it secured remained outstanding

Sommerfeldt J found, in light of the insolvency of the developer, that it was reasonable to allocate 99.9% and 0.1% of the purchase consideration to the mortgage and the debt, respectively and that “to achieve symmetry” the proceeds should also be allocated in those proportions. ...

CRA publishes a new memorandum on acceptable ITC methods for use by financial institutions

Such acquired services can “be attributed to the making of particular supplies (both taxable supplies for consideration and exempt supplies).” ...

Deans Knight – Federal Court of Appeal finds that the object and spirit of s. 111(5) is abused on an arm’s length acquisition of “actual” (albeit, not de jure) control of a Lossco

5 August 2021- 11:49pm Deans Knight – Federal Court of Appeal finds that the object and spirit of s. 111(5) is abused on an arm’s length acquisition of “actual” (albeit, not de jure) control of a Lossco Email this Content The non-capital losses of $90M, and other tax attributes of the taxpayer, were effectively sold to arm’s length investors pursuant to transactions under which: The existing shareholders of the taxpayer exchanged their shares for shares of a “Newco” (“New Forbes”) under a Plan of Arrangement A private company “facilitator” (Matco) entered into an “Investment Agreement” with the taxpayer and New Forbes pursuant to which Matco (principally in consideration for $3M in cash) acquired a debenture of the taxpayer that was convertible into shares representing 79% of its equity shares but only 35% of its voting shares. ...

You may have a TOSI issue if your investment company receives interest from a company for which your brother is an active employee

In 2019, Opco (which did not carry on a services business) redeemed its shares held by Investco in consideration for an interest-bearing term note. ...

Mony – Tax Court of Canada follows Gervais to find that avoiding capital gains attribution through ACB averaging abused ss. 73(1) and 74.2(1)

He assigned the other ½ of his shares to her in consideration for a promissory note of approximately $1M, and elected out of the application of s. 73(1), so that he realized a capital gain of approximately $1M and her ACB increased by this amount. ...

Axelrod – Tax Court of Canada finds that a dentist providing a crown or implant was supplying an exempt health care service rather than a zero-rated artificial tooth

He went on to indicate that, to determine the character of the single supply, it was necessary to determine “which element caused the payment of the consideration,” and then stated that in light of the importance of the professional services provided by Dr. ...

CRA finds that a taxpayer could not now file returns for statute-barred periods that had been arbitrarily assessed so as to claim additional expenses

However, CRA indicated that “to allow a taxpayer who has made a misrepresentation to use subparagraph 152(4)(a)(i) to reduce the amount of tax assessed would be inappropriate,” in light of various considerations. ...

We have translated 7 more CRA severed letters

Income Tax Act- 101-110- Section 110.6- Subsection 110.6(14)- Paragraph 110.6(14)(f)- Subparagraph 110.6(14)(f)(i) s. 110.6(14)(f)(i) applies to shares issued as part consideration for shares of a different class transferred to the corporation on a dirty s. 85 exchange 5 November 2003 Internal T.I. 2003-0037977 F- FRAIS POUR ANNULER UNE OFFRE D'ACHAT Also released under document number 2003-00379770. ...

Finance suggests changing the transfer-pricing rules to focus on transactions’ "economically relevant characteristics"

6 June 2023- 10:55pm Finance suggests changing the transfer-pricing rules to focus on transactions’ "economically relevant characteristics" Email this Content The consultation paper of Finance on the transfer pricing rules includes draft legislation that is under consideration. ...

CRA finds that payments made for loyalty points that had been applied to receive free services without a fixed dollar amount, did not generate ITCs

CRA indicated that the ETA s. 181 coupon rules would to some extent apply, so that: On the acceptance of the points (viewed as “coupons”) by Bco or the dealer as part consideration for the taxable supply of the widgets, they are deemed to have collected tax equal to the GST/HST that would have been collected had the points not been collected (i.e., equal to the tax fraction of the points’ value). ...

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