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CRA has an internal list of facilities which, on previous review, have been considered to be nursing homes

13 February 2017- 11:53pm CRA has an internal list of facilities which, on previous review, have been considered to be nursing homes Email this Content CRA acknowledged that it has a list of facilities that have already been reviewed to determine whether they qualify as nursing homes. ...

Birchcliff - Tax Court finds that when CRA has made a GAAR assessment, the Minister's pleadings must disclose the legislative policy that was considered to be abused

23 January 2013- 10:48pm Birchcliff- Tax Court finds that when CRA has made a GAAR assessment, the Minister's pleadings must disclose the legislative policy that was considered to be abused Email this Content Campbell J. found that the object, spirit and purpose of the Act's provisions which the Minister determined, in making a GAAR assessment, had been abused by the taxpayer, was a "material fact" that must be disclosed in the Minister's Reply. ...

CRA considers that a partnership’s affairs can be considered to have been wound-up even if title still shows land as being held for the partnership

20 May 2015- 8:35am CRA considers that a partnership’s affairs can be considered to have been wound-up even if title still shows land as being held for the partnership Email this Content The s. 85(3) rollover respecting a disposition of property by a partnership to its corporate partners requires inter alia that "the affairs of the partnership were wound-up within 60 days after the disposition. ...

QROC elections (where available) should be considered for pre-acq dividends received by a partnership

12 January 2015- 4:35pm QROC elections (where available) should be considered for pre-acq dividends received by a partnership Email this Content Pre-acquisition surplus dividends received on foreign affiliate shares held by a partnership with Canadian corporate partners do not reduce the adjusted cost base to it of those shares. ...

CRA notes factors considered in deciding to backdate an HBP withdrawal

25 October 2018- 12:03am CRA notes factors considered in deciding to backdate an HBP withdrawal Email this Content S. 146.01(2)(d) provides that for purposes of the home buyer plan rules in s. 146.01, a withdrawal from an RRSP made by an individual in January of a year “or at such later time as is acceptable to the Minister” is deemed to have been made at the end of the preceding year. ...

Vohra – Tax Court of Canada finds that support payments could be considered to be made pursuant to terms of a written separation agreement which had expired

27 December 2022- 8:57pm Vohra – Tax Court of Canada finds that support payments could be considered to be made pursuant to terms of a written separation agreement which had expired Email this Content When the taxpayer and his wife separated, they entered into separation agreement which provided for the taxpayer making support payments until December 2014. ...

Joint Committee suggests a list of examples of transactions which should not be considered to be a GAAR abuse

16 October 2023- 9:49pm Joint Committee suggests a list of examples of transactions which should not be considered to be a GAAR abuse Email this Content The Joint Committee notes that the Explanatory Notes examples regarding the proposed GAAR amendments do not reflect that many tax planning strategies utilize a series of transactions which navigates around inappropriate tax consequences in ways that likely were not specifically contemplated by Parliament. ...

CRA considers that a non-resident can be considered to be carrying on business in Canada for GST based on its agreement rather than what it ends up doing

9 November 2013- 10:06pm CRA considers that a non-resident can be considered to be carrying on business in Canada for GST based on its agreement rather than what it ends up doing Email this Content A question posed to CRA highlights an anomaly arising under the rule in ETA s. 133, which deems a supply to be made at the time the agreement for the supply is entered into. ...

Devon – Federal Court of Appeal implies that large corporations may have the right to raise new issues within one year of their Objection deadline (and finds that they can appeal new issues which were considered and rejected by CRA Appeals)

11 October 2015- 8:24pm Devon – Federal Court of Appeal implies that large corporations may have the right to raise new issues within one year of their Objection deadline (and finds that they can appeal new issues which were considered and rejected by CRA Appeals) Email this Content Although s. 169(2.1) prohibits a large corporation from appealing to the Tax Court an issue which it did not raise in its Notice of Objection, Webb JA found that where an appeals officer considers and communicates rejection of subsequently-raised issues, this has the effect of amending the Notice of Obection, so that the new issues can also be raised in a Notice of Appeal. ...

Teranet - Tax Court of Canada orders E&Y to explain why it considered a 9.75% interest rate in the Teranet income fund structure to be reasonable

24 February 2016- 7:38am Teranet- Tax Court of Canada orders E&Y to explain why it considered a 9.75% interest rate in the Teranet income fund structure to be reasonable Email this Content The conversion of Teranet to an income fund resulted in the operating corporation owing $1.23B of unsecured notes indirectly to the income fund. ...

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