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Mark Tonkovich, "A Primer on Solicitor-client Privilege and Third-party Disclosure", Tax Litigation, Volume XIX, No. 1, 2013, p. 1141. -- summary under Solicitor-Client Privilege

Generally, if the third party is providing services or analysis considered to be external to the legal retainer, the fact that the third party's work may help the lawyer formulate legal advice will not be enough to retain privilege. ...

Geoffrey S. Turner, "The New 95(2)(f.1) Carve-out Rule – Election Deadline Approaching", International Tax, CCH, 7 January 2010, No. 1974, p. 1. -- summary under Paragraph 95(2)(f.1)

Another difference is that the paragraph 95(2)(f.1) carve-out rule operates by excluding the portion of capital gain/loss or business income/loss in a foreign affiliate that can reasonably be considered to have accrued, generally, before the acquisition of control. ...

Arda Minassian, Kara Ann Selby, "Computation of Surplus Accounts", 2002 Conference Report, (CTF), c. 43 -- summary under Earnings

By virtue of the active business income generated from that resource property, FA 1 is considered to carry on a business in country B and is required to file income tax returns there as well....A technical reading of the earnings definition requires FA 1 to compute its income from its active business for the year in accordance with the income tax law of country A, but this result is not logical. ...

Mark D. Brender, Marc Richardson Arnould, Patrick Marley, "Cross-Border Cash-Pooling Arrangements Involving Canadian Subsidiaries: A Technical Minefield", Tax Management International Journal, 2014, p. 345. -- summary under Subsection 247(2)

[fn 6: … 2003-0033891E5] This statement is not to be taken to mean that there is an automatic exemption from the transfer pricing rules because of the mere existence of a specific provision that targets certain intra-group financing arrangements in a cross-border context; rather, the more specific provisions should be applied first and, if they do not apply, the application of the transfer pricing rules should be considered. ...

Ian Bradley, "Living with the Foreign Affiliate Dumping Rules", Canadian Tax Journal (2013) 61:4, 1147-66. -- summary under Paragraph 212.3(25)(b)

. … If a CRIC owned by a limited partnership is considered to be controlled by the general partner, the FA dumping rules could produce unexpected results. ...

Marc N. Ton-That, Serge Bilodeau, "Breaking Up Is Hard To Do", 96 Conference Report (CTF), p.11:51 -- summary under Paragraph 55(3.2)(h)

With the introduction of paragraph 55(3.2)(h), the sale of the shares of Holdco is subject to subparagraph 55(3.1)(b)(i), since Holdco is deemed to be a transferee and the specified shareholders of Holdco are also considered to be specified shareholders of a transferee corporation—that is, Holdco. ...

Henry Chong, "Canada and FATCA", Tax Management International Journal, 2014, p. 527. -- summary under Section 2

As a result, it appears that an entity in an IGA jurisdiction is an FFI subject to FATCA-like reporting. in that jurisdiction only if it is a financial institution under the applicable IGA, regardless of whether the entity would be considered an FFI under U S domestic law…. ...

Paul Barnicke, Melanie Huynh, "Exempt Earnings Anti-Avoidance", Canadian Tax Highlights, (Canadian Tax Foundation), Vol. 23, No. 12, December 2015, p. 5 -- summary under Subsection 5907(2.02)

However, it is questionable whether the FA's deemed disposition and reacquisition of its asset is considered a disposition of the asset by the FA to itself; a disposition to a person is a precondition of regulation 5907(2.02). ...

Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016 -- summary under Subsection 212.3(1)

., 25% or more of the CRIC's equity as measured by votes or value), then the non-resident cannot generally be considered to have caused the CRIC to make an investment in anticipation of the non-resident acquiring control of the CRIC. ...

Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016 -- summary under Paragraph 212.3(18)(a)

These rules are also subject to certain "anti-stuffing" provisions requiring additional rules around timing and "relatedness" of the CRIC, the disposing corporation/predecessor corporations and the non-resident parent which are generally designed against backing into these exceptions via what is in essence a new investment from third party vendors, which must be carefully considered. ...

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