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Michael Lang, "Income Allocation Issues Under Tax Treaties", Tax Notes International, April 21, 2014, p. 285. -- summary under Income Tax Conventions

This does not provide any clue about what applies when the regulation did not seem questionable during the negotiations or did not come under consideration…. ...

Michael Coburn, "Practical Strategies for Dealing with the Restrictive Covenant Provisions", 2014 Conference Report (Canadian Tax Foundation), 8:1-29 -- summary under Paragraph 68(c)

…[T]here would appear to be significant support for the position that two reasonable business persons would agree to allocate nil or nominal consideration to a restrictive covenant. ...

Brett Anderson, Daryl Maduke, "Practical Implementation Issues Arising from the Foreign Affiliate Dumping Rules", draft 2014 Annual CTF Coference Report paper. -- summary under Paragraph 212.3(10)(f)

However, for purposes of computing the Total Assets of Canco, the debt receivable from the Subject Corp is taken into consideration. ...

Amanda S.A. Doucette, Britney Wangler, "Normal Borrowing by CCPC Owners Can Create an Income Inclusion", Canadian Tax Focus, Vol. 7, No. 1, February 2017, p. 1 -- summary under Specified Right

In order for the bank not to have a specified right, the key consideration is that the secured property can be used only to repay the shareholder debt. ...

Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Trusts Resident in Canada", Chapter 3 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016. -- summary under Subsection 248(8)

When a person executing a disclaimer receives consideration, a question can arise whether the disclaimer is valid... ...

Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39 -- summary under Paragraph 6202.1(1.1)(c)

[P]aragraphs 66(12.66)(a.1) and (c) require that the subscription agreement and the consideration be received in the same calendar year.... ...

Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39 -- summary under Subparagraph 12(1)(x)(iv)

Consideration should be given to whether the partnership or the partner should make the election. ...

Allan Gelkopf, Robert Kreklewich, Zvi Halpern-Shavim, "Finance Canada Seeks Comments on New Tax Proposals Regarding Investment Limited Partnership Rules", Canadian Current Tax, Vol. 28, No.1, October 2017 p. 4 -- summary under Subsection 272.1(8)

The rules simply deem a certain amount of consideration, based on an arm's length fair market value test, to have been paid to the general partner and the partner is required to remit GST/HST on that amount, without regard to the partnership distributions that are paid. ...

Joint Committee, "Subsection 55(2) Amendments – Follow-Up to Our Meeting with Canada Revenue Agency", 19 January 2018 Joint Committee Submission to Finance respecting s. 2015 s. 55(2) Amendments including appended 20 April 2017 letter to Randy Hewlett on such Amendments -- summary under Subsection 55(2)

Request for Finance to consider The letter to Finance noted that CRA was able to deal only with some of the issues, which were subsequently discussed at the 2017 Annual CTF Roundtable, and asked for Finance’s consideration of these issues. ...

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114 -- summary under Ownership

The Queen, 2012 TCC 57 for the judicial consideration of the meaning of “beneficial owner” in the context of tax treaties.] ...

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