On Wednesday, the Canada Revenue Agency (CRA) released correspondence (2012-0436921I7) between Headquarters and a Large File Case Manager in a local office (TSO). Under audit was a Canadian parent company (Canco), which had invested in USD preferred shares of a…
On September 13, 2012, the Joint Committee (of the CBA and CICA) submitted a host of technical concerns with the proposed new rules relating to “foreign affiliate dumping”. Broadly, these new rules target any investments in a foreign affiliate made…
In 2011-0416181E5 (released on Wednesday), the CRA considered a US company (US Co) that offered to Canadian companies (Cancos) the ability to advertise on US Co’s website. The CRA concluded that payments by the Cancos were for advertising
Categories: Corporate Tax
Share
In Twomey v. The Queen (2012 TCC 310), the sole issue was whether shares were “issued” to the taxpayer in 1995, and not in 2005. The taxpayer argued that 100 shares were issued to him in 1995, and…
In 2011-0392171R3 (released last week) the CRA examined its previous position for share options in a company that owns Canadian real property. Under Article XIII of the Canada-US tax treaty, gains realized by US residents on Canadian real property, or…