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", International Tax Planning, 2011, p. 1136-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation Contrary to a CRA suggestion "there does not appear to be any Canadian authority requiring that a foreign entity 'issue capital stock' in order to be considered a 'corporation'.... ...

Broadhurst, "Financing by Non-Residents", 1992 Corporate Management Tax Conference Report, pp. 9:10-9:18-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) Discussion of whether a non-resident purchaser of accounts receivable would be considered to be carrying on business in Canada. ...

Joint Committee, "Avoidance of Tax Debts", 5 April 2022 Joint Committee Submission-- summary under Paragraph 160(1)(c) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(1)- Paragraph 160(1)(c) Exclusion of s. 251(5)(b) rights There should not be considered to be non-arm's length status by virtue only of rights described in s. 251(5)(b). ...

Questions of natural justice are considered to be questions of law and reviewed on the same standard:…[fn 24: Waycobah First Nation... 2010 FC 1188..., aff'd 2011 FCA 191.... ... See also Cogesco... 2013 FC 1238 at paras 18-20... and 3500722 Canada... 2008 FC 554....] the Federal Court allowed the application for judicial review on the basis that the court was unable to determine on the record whether the CRA considered certain facts that the court considered relevant: … In the early years of the administration of subsection 220(3.1), it was more common for the Federal Court to find a lack of independence within the CRA during the process of subsequent reviews. ...

.-- summary under Subsection 106(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 106- Subsection 106(2) Requirements for valid disclaimer of income interest (pp. 340 A taxpayer who executes a valid disclaimer of an income interest in a trust is generally considered not to have acquired the income interest….In order-to constitute a valid disclaimer for these purposes, the CRA's position is that the refusal must occur within a reasonable time after the recipient becomes aware of the gift or interest and before the recipient accepts any funds or benefits in respect of the gift or interest. However, if die taxpayer accepts any funds from the trust in respect of die income interest or executes a disclaimer in respect of the income interest in favour of another- person, the taxpayer is considered to have acquired the income interest and therefore cannot execute a valid disclaimer. ... Distinction between disposition and termination (p. 349) The CRA has considered a situation in which an estate of which the deceased's wife was the income beneficiary for life and her sons-were the capital beneficiaries was wound up in accordance with a court order, her income interest was terminated prematurely, and the capital was distributed to the sons. ...

Casuccio, "The Requirement to Register, Charge and Remit GST/HST on the Provision of Executor Services", Sales and Use Tax, Vol XI, No. 4, 2011, p. 598-- summary under Business Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Business Suggests (partly based on IT-377R, para. 5) that fees received from an estate by an individual who does not normally act as an executor may not be considered to be from a business. ...

", Canadian GST Monitor, August 2001 Number 155, p.1-- summary under Subsection 123(3) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(3) [P]ursuant to the Customs and Excise Offshore Application Act, the bringing of goods within the limits of the continental shelf of Canada for use as "designated goods" is considered, for purposes of Canadian customs laws, to be importation into Canada. ...

McGuffin, "Canada To Enact New Tax Avoidance Reporting Rules", Tax Management International Journal, February 8, 2013,Vol. 42, No. 2, 90 at 92-- summary under Advisor Summary Under Tax Topics- Income Tax Act- Section 237.3- Subsection 237.3(1)- Advisor Note that in some cases a counterparty could be considered an "advisor" or "promoter". ...

Firoz Ahmed, "Substituted Property for Purposes of the Section 88(1)(d) Bump", Canadian Current Tax, Vol. 7, No. 7, April 1997, p. 70-- summary under Subparagraph 88(1)(c.3)(ii) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c.3)- Subparagraph 88(1)(c.3)(ii) Where a public corporation ("Smallco") makes a successful takeover bid for another corporation ("Bigco"), RC is prepared to rule that shares of Smallco issued to shareholders of Bigco will not be considered to be substituted property by virtue of s. 88(1)(c.3)(ii) if the fair market value of the gross assets of Smallco prior to the completion of the bid is greater than 10%, but less than 50%, of the fair market value of the gross assets of Smallco after the wind-up of Bigco. ...

.-- summary under Subparagraph 88(1)(c.3)(i) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c.3)- Subparagraph 88(1)(c.3)(i) Upstream equity or debt as substituted property (p. 280) Any upstream equity interests (such as shares of the parent or other upper-tier corporate or partnership interests) or debt of any upstream entities owned after the acquisition of control will constitute substituted property since the value of such property will be considered wholly or partly attributable to distributed property. ...