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Aasim Hirji, Kenneth Keung, "Planning Possibilities Resulting from CRA Policy Reversal on Section 84.1", Tax for the Owner-Manager, Vol. 20, No. 1, January 2020, p. 9 -- summary under Subsection 129(1)

The second dividend of $250,000 is considered a taxable dividend sufficient to generate a dividend refund that fully recovers Holdco's $77,000 of non-eligible RDTOH. ...

Tim Barrett, Kevin Duxbury, "Corporate Integration: Outbound Structuring in the United States After Tax Reform", 2018 Conference Report (Canadian Tax Foundation), 18:1-76 -- summary under Non-Eligible Refundable Dividend Tax on Hand

The FAPI would be considered AII, and 302⁄ 3 percent of this amount would be added to NERDTOH (assuming that none of the restrictions apply). ...

Stan Shadrin, Manu Kakkar, David Carolin, "Application of Part IV Tax to Amalgamations of Companies Owned by Trusts with Corporate Beneficiaries", Tax for the Owner-Manager, Vol. 22, No. 1, January 2022, p. 1 -- summary under Subsection 87(2.11)

Stan Shadrin, Manu Kakkar, David Carolin, "Application of Part IV Tax to Amalgamations of Companies Owned by Trusts with Corporate Beneficiaries", Tax for the Owner-Manager, Vol. 22, No. 1, January 2022, p. 1-- summary under Subsection 87(2.11) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2.11) CRA position on year-end timing of s. 104(19) dividend (p. 1) Per 2012-0465131E5, 2016-0647621E5 and 2018-0757591I7, a dividend received and paid by a trust in a taxation year of the trust is considered to have been received by the beneficiary at the end of that year, so that the dividend payer and a corporate beneficiary need to be connected at that time in order for Part IV tax not to apply. ...

Daniel Frajman, "Update on Beneficial Ownership Transparency under the CBCA, Ontario, and Quebec Models", Tax Topics, No. 2602 (Wolters Kluwer), 18 January 2022, p. 1 -- summary under Section 2.1

Trusts (p. 4) In contrast to the CBCA rules, where individual trustees of a trust are generally considered to be individuals with control, under the QLPA such trustees are not UBs based on control, as there is no such control rule. ...

Dean Landry, Colin Mowatt, "The Uncertainty Surrounding Uncertain Tax Treatments", Perspectives on Tax Law & Policy, Vol. 4, No. 3, September 2023, p. 13 -- summary under Subsection 237.5(2)

., the reasonableness of a royalty may be considered in light of inter-affiliate charges for tangible goods. ...

David Carolin, Manu Kakkar, Paola D’Agostino, "To Redeem or Not To Redeem a Specified Shareholder: That Is the 55(3)(b) Question", Tax for the Owner-Manager, Vol. 23, No. 4, October 2023, p. 6 -- summary under Subparagraph 55(3.1)(b)(i)

S. 55(3.1)(b)(i)(C) may apply on the basis that the redemption of Dad’s preferred shares constitutes an acquisition of property by a person (DC) who ceased to be related to the vendor (Dad) as part of the series (DC will be wound-up as part of the series and, therefore, will cease to be related to Dad): it might be considered that this redemption entailed the acquisition of property by DC. ...

Joint Committee, "Section 116 of the Income Tax Act", 24 January 2025 Joint Committee submission to the Assistant Commissioner of the Compliance Programs Branch of CRA -- summary under Subsection 116(5)

That CRA adopt the position that a non-resident vendor can pay the actual amount of tax owing (rather than 25% of the gain) in order to receive a s. 116 certificate (the vendor’s payment of the actual amount of Canadian tax owing should be considered to be acceptable security respecting the disposition). ...

Ian Bradley, Jonathan Bright, "The Stop-Loss Rules and Corporate Reorganizations – Interpretive Challenges", Canadian Tax Journal, (2019) 67:2, 383-410 -- summary under Subparagraph 40(3.5)(c)(i)

. … [E]ven if a winding up … could be considered a "merger" or a "combination" under a broad operational definition of those terms, it could not be a merger or combination described in subparagraph 40(3.5)(c)(i) because it does not result in the formation of a corporation…. ... These provisions include … subsections 87(1) and (8.1) … as well as…subsection 87(8.2)…. … The exclusion of windups in the "amalgamation" and "foreign merger" definitions does not mean that every winding up would otherwise be considered a merger or combination…. ...

Brian R. Carr, Julie A. Colden, "The Bump Denial Rules Revisited", Canadian Tax Journal (2014) 62:1, 273-99. -- summary under Subclause 88(1)(c)(vi)(B)(II)

This means that in analyzing whether the bump is available, in addition to specified shareholders, other persons acquiring prohibited property and their share ownership of the target (if any) should be considered. ...

Michael Lang, "Income Allocation Issues Under Tax Treaties", Tax Notes International, April 21, 2014, p. 285. -- summary under Article 13

P has an office in State P and may therefore be considered to have a permanent establishment in State P. ...

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