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…
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…
In the Canadian domestic tax context, an accrued gain on shares held by one Canadian company in another Canadian company may be safely reduced by the payment of an inter-corporate dividend provided the gain so reduced is attributable to underlying…
In 2013-0475261E5, the CRA confirmed that a late eligible dividend designation generally should be possible where an excess capital dividend is (later) treated as a taxable dividend. An eligible dividend paid by a Canadian-controlled private corporation (CCPC) is generally…
In 2012-0439741I7 (released October 23, 2013), the CRA’s Sudbury office considered treating a Canadian company’s preferred share investment in a first-tier foreign affiliate as a loan, with the result that tax-free dividends on the preferred shares were proposed to…
In 2012-0467721R3 (released October 16, 2013), the CRA ruled that a deemed dividend paid by a Canadian unlimited liability company (ULC) to a US parent company qualified for the 5% withholding tax rate under the Canada-US tax treaty (Treaty).…
On October 15, 2013, the Joint Committee made useful submissions to Finance on draft legislation released September 13, 2013 (see http://thor.ca/blog/2013/10/department-of-finance-tax-related-quick-update-report/ for a quick summary of the latter). Among the Joint Committee’s submissions were the following items.
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In 2013-0480321C6, the CRA confirmed its view that US tax levied directly on a Canadian corporate parent (Canco) of a transparent US limited liability company (LLC) would not be deductible or creditable to Canco until such time as the…