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ILP definition

One approach would be for it to agree with the GPs to provide to them, for fees (treated as consideration for taxable supplies by it), most of the management services needed for the management by the GPs of the Opco LPs. ... The special attribution method (SAM) formula in s. 225.2(2) (as modified by SLFI Reg. 48(3)) computes additional tax or a refund as a function of net federal tax (A-B in the formula), including tax on imported taxable supplies (s. 218) and tax on qualifying consideration (s. 218.01). ... The s. 218.01 qualifying consideration rule references a qualifying taxpayer which, in the case of a non-resident partnership, includes a person with a permanent establishment (in this context, including a permanent establishment as defined in s. 132.1(2)) in Canada, as well as a non-resident partnership that (as interpreted by CRA in B-095R) is majority-owned by persons who are resident in Canada or carry on business in Canada or conduct activities there. ...

21 November 2017 CTF Annual Conference Roundtable

A Folio is our web-friendly technical publication that takes consideration of the state of the law, and relevant Tax Court decisions and technical interpretations that the CRA has produced up until the date of the Folio publication. ...

Subsection 212.3(15) - Commentary

Parent incorporates a Canadian-resident corporation (Buyco), which acquires all the shares of Canco (whose only asset is a non-resident subsidiary) in consideration for an obligation of Buyco to cause the issuance of shares of Parent to the public shareholders of Canco. ...

29 May 2018 STEP Roundtable - Official Response

In some of these circumstances, consideration can be given to whether it may be better for taxpayers to determine whether the amount is excluded from the TOSI because it is a reasonable return of the individual based on the factors applicable in the circumstances. ... Section 84.1 achieves its purposes by: (1) reducing the paid-up capital of the shares of the subject corporation, which reduces the ability to return paid-up capital of the purchaser corporation as the excess would be taxed as a dividend, and (2) deeming the individual shareholder to have received a dividend where the purchaser corporation pays non-share consideration for the shares of the subject corporation that exceeds the greater of the paid-up capital and the “hard ACB” of the particular shares transferred. ...

7 October 2022 APFF Roundtable

As provided for in subsection 256(5.11) and the applicable jurisprudence, any factor, whether contractual, commercial, economic, moral or familial, may be taken into consideration in order to determine whether a person or group of persons has influence, direct or indirect, the exercise of which would result in de facto control of a corporation ("Influence"). ... Under paragraph 80(2)(a), an obligation issued by a debtor is settled at any time where the obligation is settled or extinguished at that time (otherwise than by way of a bequest or inheritance or as consideration for the issue of a share described in paragraph (b) of the definition excluded security in subsection 80(1). ...

19 June 2015 STEP Roundtable

However, it is not uncommon for a shareholder to request an S Corporation agreement and, while the request is under consideration, file the Canadian returns in the expectation that an S Corporation agreement will be provided. ...

6 October 2017 APFF Roundtable

A's right under the Initial Trust constituted a beneficial interest, if subsection 248(25) applied without taking into consideration subdivisions (b)(iii)(A)(II) to (IV) thereof. ...

21 November 2017 CTF Annual Conference CRA Roundtable - Official Response

The initial folios workload was prioritized for action based on considerations that included: feedback received through internal and external consultations to identify the public need for guidance in each technical subject area; and the availability of resources to prepare the required updates. ...

27 November 2018 CTF Roundtable

Example 4: Shareholders of DCco transfer shares of DCco having an aggregate PUC of $10,000 and an ACB of $1,000 to TCco in consideration for shares of TCco. ...

10 October 2024 APFF Financial Strategies & Instruments Roundtable

Finally, consideration should be given to the possible application of other provisions of the Income Tax Act, depending on the facts and circumstances of the particular situation, such as subsection 56(2), if it were otherwise determined that the loan was not made in good faith. ...

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