In Mckesson Canada Corporation v. The Queen, 2013 TCC 404, the Canadian company in the group (Canco) sold its trade receivables to a Luxembourg company in the group (Luxco) at a discount of 2.206% (from their face amount). In an…
In 2013-0512551I7, the CRA confirmed that Canadian GAAP governs a corporation’s retained earnings for thin capitalization purposes, not the income allocation rules for partnerships in s. 96. In broad terms, a Canadian corporation (Canco) cannot deduct interest expense on…
In 2013-0514701I7, the CRA confirmed that transactions involving bitcoins should be reported as would any other barter transaction. The bitcoin is a virtual currency used to buy and sell goods and services on the Internet. It is not a…
At the age of 19, Eugenie Bouchard made all Canadians proud with her stellar performance at the 2014 Australian Open. Behind the tennis star is more than a decade’s training paid for by her father. Mr. Bouchard thought he found…
On January 9, 2014, the Government of Canada released for public comment draft legislative proposals that – if enacted – will require the reporting of international electronic funds transfers of $10,000 or more to the Canada Revenue Agency effective as…
In Devon Canada Corporation v. The Queen, 2013 TCC 415, the Tax Court of Canada (TCC) held that the “successor” resource rules continued to apply in favor of the taxpayer, even though the resource properties in question had been…
In 2013-0499681E5, the CRA confirmed that dissolution of a top-tier partnership eliminates any reserve for qualifying transitional income (QTI) in respect of that partnership. The 2011 federal budget eliminated the deferral of corporate tax through the use of partnerships…
In 2013-0484031E5, the CRA confirmed that a partnership is not a “person” that can acquire legal control of a corporation. Rather, the CRA will look to which partner (or partners) can legally exercise voting rights in respect of the…