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Joint Committee, "Legislative Proposals to Address Income Sprinkling Released December 13, 2017", 8 March 2018 Joint Committee Submission -- summary under Paragraph 120.4(1.1)(b)

Son, who inherits Opco shares from them, inherits the attributes of Mother so that Opco’s business is considered an “excluded business” of Son for the remainder of his lifetime. ...

Paul Cormack, Janette Pantry, "Partnership Reorganizations", Canadian Tax Highlights, Vol. 26, No. 6, June 2018, p. 5 -- summary under Subsection 98(5)

If the construction business carried on by Bco is considered to be the same business carried on by the partnership (a question of fact), subsection 98(5) automatically applies and overrides subsection 98(3). ...

Anthony Strawson, Timothy P. Kirby, "Vendor Planning for Private Corporations: Select Issues", 2017 Conference Report, (Canadian Tax Foundation), 11:1-28 -- summary under Subsection 249(3.1)

This provision should be considered by CCPC vendors and their shareholders when entering into any share sale transactions with foreign buyers or public corporations that could result in a change of control. ...

David G. Duff, "Tax Treaty Abuse and the Principal Purpose Test – Part 2", Canadian Tax Journal, (2018) 66:4, 947-1011 -- summary under Subsection 245(4)

This conclusion is consistent with the language of subsection 245(4) of the ITA as it read at the time of the decision in OSFC, which provided that section 245 would not apply to an avoidance transaction where it was reasonable to conclude that the transaction did not result in a misuse or abuse, but is not consistent with the amended language of this provision, which provides that section 245 applies to an avoidance transaction if such transaction may reasonably be considered to result in a misuse or abuse. ...

Simon Cheung, "Private Foundations: Exceeding the 20 Percent Limit", Canadian Tax Focus, Vol. 9, No. 2, May 2019, p. 5 -- summary under Subsection 188.1(3.1)

Is the debt considered an “interest”…? In a technical interpretation … the CRA takes [that] interpretation. ...

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, 1999 CanLII 466 (TCC), at paragraphs 37-38] Beneficial owner equates to the real owner of property (p. 20:90) Although the term “beneficial ownership” is not defined in the Act and its meaning has been the subject of much debate, it has been considered, in the jurisprudence, to mean the “real owner of the property” possessing the right to enjoy, and assuming the risk of loss in respect of, the property. ...

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114 -- summary under Paragraph 5907(11.2)(b)

[F]iscally transparent entities, such as LLCs, are generally not considered treaty residents. ...

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114 -- summary under Subclause 95(2)(a)(ii)(B)(II)

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Subclause 95(2)(a)(ii)(B)(II) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(B)- Subclause 95(2)(a)(ii)(B)(II) Dubious textual interpretation of s. 95(2)(a)(ii)(B)(II) (“Cap B”) in 2016-0680801I7 (pp. 20:65-69) The CRA recently considered the application of Cap B in recharacterizing interest income earned by an inactive FA that has made a loan to a partnership that was not wholly owned by the CRIC’s group. ...

H. Michael Dolson, "Can a Tax Refund Be Paid to a Third Party? Section 116 and Foreclosures", Canadian Tax Focus, Vol. 10, No. 2, May 2020, p. 8 -- summary under Section 67

It also may be considered to make a more general point: taxpayers should be allowed to direct where their refunds are to be paid, just as they choose the bank account into which the funds are to be deposited. ...

PWC, "Tax Insights: Investment limited partnerships ─ GST/HST & QST filing obligations", Issue 2020-27, May 04, 2020 -- summary under Subsection 225.4(6)

PWC, "Tax Insights: Investment limited partnerships ─ GST/HST & QST filing obligations", Issue 2020-27, May 04, 2020-- summary under Subsection 225.4(6) Summary Under Tax Topics- Excise Tax Act- Section 225.4- Subsection 225.4(6) Addition of ILPs to SLFI world Most Canadian resident investment limited partnerships (ILPs) will be considered to be a Selected Listed Financial Institution (SLFI), starting January 1, 2019 (i.e. the 2019 fiscal year). ...

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