93 C.M.TC - Q.16
Discussion of the circumstances in which the Canadian competent authority had permitted deferral of recognition of gain.
90 C.P.T.J. - Q.30
In determining the taxpayer's gain or income for Canadian income tax purposes, the taxpayer may choose whether or not to elect to reduce the...
Dalsin, "Dispositions of Property by Non-Residents: Tax Deferral by Ministerial Discretion", 1991 Canadian Tax Journal, p. 77.
D'Aurelio, "International Issues: A Revenue Canada Perspective", 1990 Conference Report, c. 44, under "Section 115.1 and Related Treaty Provisions"
Sifto Canada Corp. v. The Queen, 2017 TCC 37
CRA accepted a voluntary disclosure by Sifto Canada that it had undercharged on its sales of rock salt to a U.S. affiliate, and reassessed...
|Locations of other summaries||Wordcount|
|Tax Topics - Treaties - Income Tax Conventions - Article 9||agreement with the U.S. competent authority re a VDP-adjusted transfer price binds CRA even if it had not yet audited the taxpayer||593|
|Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2)||TNMN method was reasonable||211|
|Tax Topics - Income Tax Act - Section 152 - Subsection 152(1)||MAP agreement concurred in by taxpayer was binding on the Minister as it was not “indefensible”||265|