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Conference
9 November 2012 CTF Atlantic Roundtable, 2012-0465921C6 - CTF Atlantic - Statute Barred Years
Would a tax avoidance arrangement generally be considered a misrepresentation? ...
Conference
15 June 2022 STEP Roundtable Q. 18, 2022-0924791C6 - McNeeley et al v. The Queen
The issues considered in the case The issues which the Tax Court had to consider included the following: 1. ...
Conference
8 May 2012 Roundtable, 2012-0435641C6 - CALU CRA Roundtable Question 6 – May 2012
In the 1993 CRA View 9323775, the CRA commented that: “To be included in the determination of the CDA of a corporation the proceeds must be considered to be received by the corporation. If the amounts are received by a trust, other than a bare trust, and then distributed to the corporation, they are not considered to be insurance proceeds, rather they are a distribution from a trust…. ... The CRA has on numerous occasions set out requirements for a trust to be considered a bare trust and thus effectively ignored for the purposes of the Act. ...
Conference
21 November 2017 CTF Roundtable Q. 11, 2017-0724081C6 - ULC-LLC structures & Treaty
CRA Response Article IV(6) of the Treaty provides that an amount of income, profit or gain shall be considered to be derived by a person who is a resident of the U.S. ... Furthermore, pursuant to the Technical Explanation to the 2007 Protocol to the Treaty, where Article IV(6) applies to deem a U.S. resident to be considered to derive a Canadian-source dividend, such dividend is considered as being paid to that U.S. resident. As such, dividends paid by the ULC in the example provided above would be considered as being paid to USCo1 and USCo2. ...
Conference
15 May 2019 IFA Roundtable Q. 4, 2019-0798721C6 - 78(1)(b)(ii) deemed loan & thin capitalization
Where a debt bears only simple interest, any accrued and unpaid simple interest itself will not be considered to be an outstanding debt to a specified non-resident. Even where the simple interest bears compound interest, that simple interest will not be considered to be an outstanding debt to a specified non-resident until the compound interest is paid and is therefore deductible in accordance with paragraph 20(1)(d) of the Income Tax Act (the “Act”). ... (b) Where compound interest does accrue on unpaid simple interest and subparagraph 78(1)(b)(ii) deems the amount of that simple interest to be a loan, is that deemed loan considered to be an outstanding debt to a specified non-resident only when the compound interest has been paid? ...
Conference
10 June 2016 STEP Roundtable Q. 7, 2016-0634911C6 - Deemed Resident Trust and CCPC Status
Deemed Resident Trust and CCPC Status A trust which meets the conditions of section 94 is considered resident for certain purposes of the Income Tax Act (the “Act”). ... Since subsection 94(3) does not state that a deemed resident trust is considered resident for purposes of determining control, we would imagine that the corporation would not be considered Canadian controlled. ... Therefore, we can confirm that Opco will not be considered a CCPC as a result of the fact that Trust is deemed resident in Canada by virtue of section 94. 2016-063491 Katie Campbell ...
Conference
26 May 2005 Roundtable, 2005-0126031C6 - Carrying on an Insurance Business
The investment activities are such that, either under ordinary income tax principles or pursuant to section 253 of the Act, the insurer would be considered to be carrying on business in Canada. ... The business the insurer is carrying on (or deemed to be carrying on) would not be considered an insurance business carried on in Canada by the insurer for purposes of the Act. ... It does not carry on any activities that in Canada would result in it being considered to carry on an insurance business for purposes of the Insurance Companies Act (Canada) or similar provincial legislation. ...
Conference
21 November 2017 CTF Roundtable Q. 15, 2017-0724091C6 - Conversion from a US LP to an LLC
The conversion from a USLP to an LLC would generally be considered, from a Canadian tax perspective, to be from one form of legal entity to another (i.e. from a partnership to a corporation). ... The above comments should be considered whenever there is a conversion, from a Canadian tax perspective, from a partnership to a corporation. ... These comments are general in nature, and other specific rules might have to be considered depending on the facts and circumstances of a particular case. ...
Conference
18 November 2014 Roundtable, 2014-0550401C6 - 2014 TEI Liaison Meeting, Q. E3
Position: 1) Generally a tender offer (i.e. an offer which requires an acceptance by the holder in the form of a tender of the relevant obligation by the holder directly to the issuer) is not considered to be an open market repurchase for purposes of subsection 39(3). 2) Generally, a bond repurchase that is negotiated and concluded directly between an issuer and a holder is not considered to be an open market repurchase for purposes of subsection 39(3). 3) Generally, the exercise by the issuer of an early repayment right pursuant to the terms of a bond is not considered to be an open market repurchase for purposes of subsection 39(3). ... Generally a bond repurchase that is negotiated and concluded directly between an issuer and a holder is not considered to be an open market repurchase for purposes of subsection 39(3). Generally the exercise by the issuer of an early repayment right pursuant to the terms of a bond is not considered to be an open market repurchase for purposes of subsection 39(3). ...
Conference
8 May 2012 Roundtable, 2012-0435771C6 - CALU CRA Roundtable – May 2012 - Question 10
There is no case law which provides guidance on when an interest of an employer in an insurance policy “may reasonably be considered to be acquired to fund, in whole or in part,” in the context of subsection 207.6(2). ... Has the CRA considered whether subsection 207.6(2) could apply to segregated fund policies and if yes, in what circumstances? CRA Response The CRA has not previously considered the RCA deeming rule in the context of segregated fund policies. ...