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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. ...
21 November 2017 CTF Annual Conference CRA Roundtable - Official Response
Miscellaneous correspondence
Further, these transactions contravene one of the underlying principles of the taxation of the capital gains regime which is to prevent the indefinite deferral of tax on capital gains and which is supported by subsections 70(5), 104(4) and 107(2). ...
SCC (summary)
Canada (Attorney General) v. British Columbia Investment Management Corp., 2019 SCC 63, [2019] 4 SCR 559 -- summary under Section 125
., 2019 SCC 63, [2019] 4 S.C.R. 559-- summary under Section 125 Summary Under Tax Topics- Other Legislation/Constitution- Constitution Act, 1867- Section 125 ETA taxes that would be borne by portfolio of which a Crown agent was legal owner would contravene s. 125 BCI was a B.C. ... In finding that such assessments would contravene s. 125 of the Constitution Act, 1867 but for the effect of Intergovernmental Agreements between B.C. and the federal government, Karakatsanis J first noted that such a contravention would require that “the subject matter of the tax must be property belonging to the federal Crown in the case of a tax imposed by the provincial legislature and to the provincial Crown in the case of a tax imposed by Parliament” (para. 68), before stating (at para. 76): BCI, as trustee, legally owns the assets held in the Portfolios. ...
Technical Interpretation - External summary
15 June 2020 External T.I. 2020-0850981E5 - CECRA – Pension plan eligibility -- summary under Clause 149(1)(o.2)(ii)(C)
. … [O]ur views are as follows: Participating in the CECRA with respect to commercial property held by a pension real estate corporation will not contravene the borrowing restriction in clause 149(1)(o.2)(ii)(C). Although participating in the CECRA by an RPP will contravene the narrower borrowing restriction in paragraph 8502(i), the CRA will exercise its discretion to not revoke the registration of an RPP for failure to comply with this condition. ...
Technical Interpretation - External summary
15 June 2020 External T.I. 2020-0850981E5 - CECRA – Pension plan eligibility -- summary under Paragraph 8502(i)
. … [O]ur views are as follows: Participating in the CECRA with respect to commercial property held by a pension real estate corporation will not contravene the borrowing restriction in clause 149(1)(o.2)(ii)(C). Although participating in the CECRA by an RPP will contravene the narrower borrowing restriction in paragraph 8502(i), the CRA will exercise its discretion to not revoke the registration of an RPP for failure to comply with this condition. ...
Conference summary
3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 6, 2023-0994241C6 F - Consequences of Transfer of DSUs to a corporation -- summary under Salary Deferral Arrangement
(l) exclusion after such a transfer, so that the FMV of the deferred share units would be included in computing the employee's income in the year of the transfer (to the extent that such value had not already been included), CRA stated: A transfer to another person would contravene the preamble to paragraph 6801(d), which requires that the agreement be between the corporation and the employee and that it be that employee who may receive amounts under the arrangement. Furthermore … the transfer of the employee's rights in the DSU Plan could indirectly allow the individual to access the value of the individual's rights before one of the times specifically identified in paragraph 6801(d)(i) … which would also contravene the requirements of paragraph 6801(d). ...
ABPC summary
R. v. Marcoux, 85 DTC 5453, [1985] 2 CTC 254 (Alta. Prov. Ct.) -- summary under Section 8
.)-- summary under Section 8 Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982)- Section 8 3rd party seizure invalid "The completely arbitrary and discretionary power of seizure from third parties" conferred by s. 231(3) was found to contravene s. 8. ...
Decision summary
Darbishire v. The Queen, 83 DTC 5164 (Ont. Co. Ct.) -- summary under Subsection 239(2)
Nor does the discretion granted to the Crown by s. 239(2), or the exercise of that discretion, contravene ss.11(d) or 9 of the Charter. ...
ONCA summary
R. v. Century 21 Ramos Realty Inc., 87 DTC 5158, [1987] 1 CTC 340 (Ont.C.A.) -- summary under Subsection 15(1)
.)-- summary under Subsection 15(1) Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982)- Subsection 15(1) The Attorney General's right of election in s. 239(2) does not contravene s. 15 of the Charter. ...
ABCA summary
Medicine Hat Greenhouses Ltd. v. R., 81 DTC 5100, [1981] CTC 141 (Alta. C.A.) -- summary under Paragraph 239(1)(d)
S.239(1)(d) does not make it an offence per se to contravene s. 18. The onus remained on the Crown throughout to establish evasion, and the willfulness of that evasion, beyond a reasonable doubt. ...