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23 February 2016 Toronto Centre Tax Professionals - Approach to Large Business Audit Compliance - Update

Where, based on risk assessment and the regional work plans, we find that a TSO has more high-risk cases than they can complete based on their current work in progress, based on their resources, based on their technical capacity, and perhaps based on their industry knowledge, those additional cases that are identified will then be considered for workload portability. ... Where the risk is considered low, we'll try and close those files, and what remains would be high-risk, old outstanding years. ... If there are recurring issues, if the taxpayer is considered high risk, if the taxpayer has been less than transparent and cooperative with the CRA, then we will consider going back into earlier years to address those high-risk issues. ...

26 May 2016 IFA Roundtable

Oral Response Dave Beaulne: In addition to speaking about this issue at the Canadian Tax Foundation in November, we spoke about it at last year's IFA conference in Calgary, where we outlined several factors being considered in the analysis. ... We will reiterate a couple of the factors that we considered to be of overwhelming significance- those being: legal personality- I know we went down that road a number of years ago, but these entities that we were asked to opine on [i.e. ... Our understanding is that US Parent, US Sub, and the ULC are all considered as fiscally transparent for U.S purposes, so for purposes of subparagraph 7(b), we are looking at the "same treatment" test for U.S. purposes under which there is a comparison between the treatment if the interest had been paid by the ULC as a fiscally transparent entity, or as a corporation that is not fiscally transparent. ...

17 May 2022 IFA Roundtable - Finance Update

My question is, in the case of a foreign taxation year that straddles the coming into force on July 1 st 2022, can you confirm that the deemed amount should not include the portion of the deductible amount for that year that could be considered to arise before the July 1 st 2022 date? ... It was a choice between that, and implementing the primary recommendation of having a more formal registration scheme, with reference numbers and things like that, and we considered that approach to be too onerous. ... In the BEPS Action 12 report, those were considered to be inconsistent with the use of a main purpose test. ...

28 May 2025 IFA Roundtable - Written Response

As was pointed out in CRA document 2017-0682631I7, the automatic cash sweeps that occur as part of a physical cash pooling arrangement would likely be considered to form part of a “series of loans or other transactions and repayments”. ... The anticipated frequent and ongoing movements in the account balances of participants to a notional cash pooling arrangement would likely be considered to form part of a “series of loans or other transactions and repayments”. ... Would CCA under the Act be considered to have been claimed for taxation years that ended before US LLC became a foreign affiliate of Canco? ...

3 February 2021 Transfer Pricing Conference - Selected topics panel

Admittedly, the CRA might have considered the proposed amendment to represent a change if it had been asked 15 years ago, but the new wording accords with the CRA’s current positions. ...

26 April 2017 IFA Roundtable

Official Response Official response Q.5 S. 91(4.7) and Brazilian deductible dividends Foreign tax credit generator (FTCG) rules in subsections 91(4.1) to (4.7) deny a deduction for foreign accrual tax (FAT) if a “specified owner” is considered under relevant foreign law to own less than all shares of a particular corporation than it is considered to own under the Act (Lesser Ownership Test). ...

20 November 2017 CTF Annual Conference - Department of Finance on BEPS

Because the other provisions were not minimum standards, it was considered that there should be more flexibility as to whether or not to pick up those provisions. ... Response Stephanie Smith: As tools to interpret the MLI, we have the Explanatory Statement, which was developed by the entire ad hoc group, developed at the same time as the instrument, and so it definitely is a tool that should be considered, I think that is consistent with the Convention that it would be an applicable tool. ...

15 September 2020 IFA Roundtable

If so, assuming that one or more of the steps that are part of the series of transactions is an avoidance transaction, would the CRA be of the view that they would reasonably be considered to result in a misuse or abuse of the provisions of the Act such that subsection 245(2) would be applicable? ... One (or more) of the members of LP is a corporation resident in Canada (Canco2) that has a sufficient partnership interest in LP, such that FA is considered to be a foreign affiliate of that corporation as defined under subsection 95(1) of the Income Tax Act (Act) for the purposes described in subsection 93.1(1.1) of the Act. ...

Purchaser - Commentary

This approach is accepted in Bulletin PST 319, which states that "unless a written partnership agreement provides otherwise…each partner is considered to own a proportionate share of the partnership assets equal to that partner's interest in the partnership. ... Accordingly, a purchase by the general partner was considered to come within the expanded definition of "purchaser," which refers to a person who acquires tangible personal property as agent – so that a purchase by the general partner was subject to full tax notwithstanding that the vendor had a proportionate interest as limited partner in the partnership. This approach also is accepted in Bulletin PST 319, which states that "unless a limited partnership agreement provides otherwise in writing, any transaction involving the limited partnership is considered to be a transaction with the general partner(s)" and that the acquisition of a limited partnership interest is not considered to be an acquisition of partnership assets, so that no PST is payable. ...

Paragraph 2(3)(b) - Commentary

Similarly, the soliciting of orders in the UK through an agent was not sufficient to result in a non-resident being considered to exercise its wine trade there (Grainger). ... London Life) Where the business in question is one of trading in property, the business generally will be considered to be carried on where the contracts are made (Geigy, Sudden Valley, Belfour v. ... In order for the non-resident to be considered to be carrying on business in Canada, the activity in question must constitute the carrying on of a business. ...

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