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21 November 2017 CTF Annual Conference Roundtable
Roundtable notes
In fact, we are of the view that they contravene one of the underlying principles for the taxation of capital gains, which is that the gain that accrued in Canada should be taxed. ... Otherwise, it results in the circular calculation that contravenes the scheme of s. 55(2). ...
29 November 2016 CTF Annual Conference Roundtable
Roundtable notes
In CRA’s view, this contravenes one of the underlying principles for the taxation of capital gains, which is to prevent the indefinite deferral of tax on capital gains. ...
8 October 2021 APFF Roundtable
Roundtable notes
CRA Preliminary Response Generally, a personal trust may carry on a business as long as this does not contravene its governing document. ... Generally, the CRA will recognize the legal effect of a counter letter for tax purposes to the extent that: the counter-letter has effective legal effects and does not contravene any legislation; the counter-letter is not a sham; the counter-letter is entered into before or at the same time as the apparent contract and is not an ex post facto arrangement; the terms of the counter letter are disclosed to the CRA and the relevant documents in that regard are provided to the CRA in a timely manner; and the facts of the particular situation are consistent with the legal relationship of the parties as described in the counter letter. ...
13 June 2017 STEP Roundtable
Roundtable notes
This contravenes one of the underlying principles in the regime for the taxation of capital gains, which is to prevent the indefinite deferral of tax on capital gains. ...
6 October 2017 APFF Roundtable
Roundtable notes
This contravenes one of the underlying principles in the taxation of capital gains regime, which is to prevent the indefinite deferral of tax on capital gains. ...