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Michael Lang, "Income Allocation Issues Under Tax Treaties", Tax Notes International, April 21, 2014, p. 285. -- summary under Article 13

The considerations made by the Canadian courts regarding treaty law are based on the assumption that Austria treats the private foundation as a taxpayer, while Canadian tax law treats it as transparent. ...

Michael McGowan, "HMRC v Lloyds Bank Leasing (No 1) Ltd: the troublesome increase in the scope of the "sole or main object" test", [2015] British Tax Review, No.5 2015 (Thomson Reuters (Professional) UK Limited), p. 649 -- summary under Purpose/Intention

.'" [f,n, 13...[48]] However, in this case, it did not in fact matter whether one looked directly at the intentions of relevant parties other than K-Line or examined them through K-Line's eyes: K-Line must have been aware that tax was a consideration for all parties. ...

Joint Committee, "Part D of Tax Planning Using Private Corporations – “Converting Income into Capital Gains” Proposals", 2 October 2017 Joint Committee Submission -- summary under Paragraph 84.1(2)(a.1)

Example 4 Bob sells the shares of Opco (having a FMV of $6 million and nominal PUC and ACB) directly to his children, and receives a $6 million promissory note as consideration. ...

Anthony Strawson, Timothy P. Kirby, "Vendor Planning for Private Corporations: Select Issues", 2017 Conference Report, (Canadian Tax Foundation), 11:1-28 -- summary under Subsection 84.1(1)

GAAR analysis of use of s. 84.1 (p. 11:24) [O]n initial consideration, reliance on a specific anti-avoidance rule to obtain a beneficial tax deferral seems to fall within the scope of abusive tax avoidance because “the outcome defeats the rationale of the provision relied upon.” ...

Kenneth Saddington, Jennifer Hanna, "Mergers and Acquisitions in the Light of the US Tax Changes", 2018 Conference Report (Canadian Tax Foundation), 19:1-36 -- summary under Subsection 249(3.1)

[Fn. 52. paragraph 251(5)(b) and subsection 249(3.1)] The Canadian target would incorporate a new Canadian subsidiary (“Newco”) and transfer all of the assets that constitute the business, including the IP, to Newco in consideration for common shares. ...

Jim Samuel, Byron Beswick, "Selected Issues in Transactions Involving Debt", 2019 Conference Report (Canadian Tax Foundation), 18:1 – 27 -- summary under Subsection 18(9.1)

Alternatively, if the intermediary is considered to be in the business of lending money, consideration could be given to whether the penalty paid might be deductible, under section 9 …. ...

Barbara M. Angus, "Chipping Away at the Permanent Establishment Concept", Tax Management International Journal, Vol. 42, No. 5 May 10, 2013, p. 259. -- summary under Article 5

The fact pattern under consideration here seems to have been inspired in part by the 2001 decision of the Norwegian Supreme Court in Offshore Accommodation Service AB v. ...

Steve Suarez, "Canada's 88(1)(d) Tax Cost Bump: A Guide for Foreign Purchasers", Tax Notes International, December 9, 2013, p. 935 -- summary under Subparagraph 88(1)(c.3)(i)

Note, however, that this exception does not extend to stock options issued for other consideration — for example, options issued to subsidiary employees as an incentive to remain with the company post-AOC [acquisition of control].] ...

J. Harold McClure, "Evaluating Whether a Distribution Affiliate Pays Arm's-Length Prices for Mining Products", Journal of International Taxation, July 2014, p. 33. -- summary under Subsection 247(2)

Such differences in operating costs may occur because of differences in the range; of functions performed, the intensity with which they are performed, efficiency considerations (e.g., economies of scale) Or access to unique intangibles... ...

Pierre-Marie Hourdin, "Is the Construction PE Clause in the OECD Model Treaty Satisfactory?", Tax Notes International, July 21, 2014, p. 229. -- summary under Article 5

Legal certainty and administrative considerations also imply that the company should be able to anticipate its PE situation before the work begins. ...

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