Category: Corporate Tax

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

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…