In 2014-0536661R3, the CRA issued an advance income tax ruling concerning a situation where a Canadian public company will consolidate property held by its controlled foreign affiliates and a wholly-owned foreign LP.
The CRA confirmed that a distribution of certain property…
In 2015-0574291I7, the CRA considered whether Part XIII tax was exigible on an early termination payment made by a Canadian resident corporation (Canco) to a foreign resident corporation (Forco).
Canco made the early termination payment to Forco as consideration…
In Minister of National Revenue v. BP Canada Energy Company, 2015 FC 714, the Federal Court ordered BP to hand over tax accrual working papers that the Canada Revenue Agency (CRA) requested in the course of its audit. Tax accrual…
On June 9, 2015, the CRA released an updated version of its Income Tax Folio on related persons and dealing at arm’s length: “Related persons and dealing at arm’s length” (S1-F5-C1).
Among other things, the updated version adds paragraph 1.44.1,…
In Harvest Operations Corp v Canada (Attorney General), 2015 ABQB 327, the Alberta Court of the Queen’s Bench denied an application for rectification, holding that parties who are seeking rectification “need to demonstrate more than just a general intent to…
In Kruger Incorporated v. Her Majesty the Queen (2015 TCC 119) the Tax Court of Canada concluded that, for the purposes of computing taxable income, the taxpayer could not value its foreign exchange option contracts on a mark to market…