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Ian Gamble, "Income from a Business or Property: General Principles and Current Issues", 2014 Conference Report, Canadian Tax Foundation, 5:1-32 -- summary under Paragraph 111(5)(a)

For the parent that has crossed this line, losses from this source—including interest expense deductible under paragraph 20(l)(c)—are considered losses from business, not from property. ...

Hugh J. Ault, "Some Reflections on the OECD and the Sources of International Tax Principles", Tax Notes International, 17 June, 2013, p. 1195 -- summary under Article 25

Ault, "Some Reflections on the OECD and the Sources of International Tax Principles", Tax Notes International, 17 June, 2013, p. 1195-- summary under Article 25 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 25 After referring to the 1998 release by the OECD of a report on harmful tax competition that signaled an important change of focus in international cooperation efforts and to the OECD's base erosion and profit shifting (BEPS) project, he considered the following case. ...

Jamie M. Wilks, "Educating and Training Vocational Schools and Other Educational Institutions How to Comply With Complex GST/HST Rules", Sales and Use Tax, Volume XII, No. 3, 2013, p. 638. -- summary under Section 8

Notwithstanding that the Taxable Election is made under section 6 or 8 to tax the courses or educational services, these supplies could still be considered exempt under section 1 of Part V.1 (the general exemption for supplies made by charities). ...

Mike J. Hegedus, "Paragraph 40(2)(e.1) Versus Subparagraph 40(2)(g)(ii): Potential Conflict?", Resource Sector Taxation (Federated Press), Vol. IX, No. 4, 2014, p.684. -- summary under Paragraph 40(2)(e.1)

S. 40(2)(e.1) should have paramountcy over s. 40(2))(g)(ii) (pp. 688-9) Even if the CRA was of the view that subparagraph 40(2)(g)(ii) may otherwise have been applicable in Ruling 2008-0300161R3, paragraph 40(2)(e.1) should be considered to have paramountcy over subparagraph 40(2)(g)(ii). ...

Paul Stepak, Eric C. Xiao, "The 88(1)(d) Bump – An Update", 2013 Conference Report (Canadian Tax Foundation), pp.13:1-60 -- summary under Paragraph 88(4)(b)

[W]e submit that paragraph 88(4)(b), when read in context, should reasonably be considered to have the effect of deeming the securities of Amalco to be the same as the securities of the predecessor corporation…. ...

Ian Caines, Chris Van Loan, "Character Conversion Transactions and Synthetic Disposition Arrangements Updated", Corporate Finance, Volume XIX, No. 1, 2013, p. 219. -- summary under Derivative Forward Agreement

.-- summary under Derivative Forward Agreement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Derivative Forward Agreement Economic exposure requirement (p. 2198) …before a sale agreement will be considered to be a DFA [derivative forward agreement], the agreement must be part of an "arrangement" that has the effect of eliminating a majority of the taxpayer's risk of loss and opportunity for gain or profit with respect to the property (which we will refer to as "economic exposure")…. ...

Robert Demers, "Indirect Tax considerations in M&A Due Diligence", 2015 CTF Annual Conference paper -- summary under Subsection 296(2.1)

The tax authorities may not allow taxes added to credit notes to be considered taxes paid in error (to my knowledge, there is an unpublished interpretation regarding this matter in the bank of available tax interpretations). ...

Henry Shew, Jody Wong, "Multi-Level Farming Structures and the Capital Gains Exemption", Canadian Tax Focus, Vol. 6, No. 3, August 2016, p. 10 -- summary under Share of the Capital Stock of a Family Farm or Fishing Corporation

Nevertheless, the CRA has stated that when a partnership carrying on a farming business has only one level of corporate partners, the corporate partner will be considered to carry on the business of the farm partnership (…2008-029974117). ...

Nathan Boidman, Peter Glicklich, Michael Kandev, "Canada's New Approach to U.S. LLPs and LLLPs", Tax Management International Journal, 2016, p.479 -- summary under Corporation

For those deemed dispositions, there may not be "roll-over" treatment available to defer or avoid immediate Canadian tax; such impacts must now be carefully considered. ...

Manon Thivierge, "Income Tax Due-Diligence Considerations in Mergers and Acquisitions", 2015 Conference Report (Canadian Tax Foundation), 18:1-29 -- summary under Subsection 89(11)

. … A possible solution is for the target to elect not to be considered to be a CCPC under subsection 89(11). … [T]he election applies only for the purposes described in paragraph (d) of the definition of CCPC in subsection 125(7) —namely, the small business deduction and provisions relating to the GRIP and the LRIP—as well as subsection 249(3.1). ...

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