4 March 2023 Internal T.I. 2023-0994501I7 - Non-resident non-arm's length transfer of property

Unedited CRA Tags

13(7)(e), 248(1) - definition of taxpayer, 54 - definition of capital property, 13(21) - definition of depreciable property, 20(1)(a), ITR 1102(3)

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Summaries

Summary Under

s. 13(7)(e)(ii) applies to the purchase of a depreciable property from a non-arm’s length non-resident corporation with no tax nexus to Canada

A non-resident corporation (“US Corp”) sold trademarks at a sales price in excess of their adjusted cost base to a non-arm’s length Canadian...

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Summary Under

Oceanspan inapplicable where the non-resident’s Canadian tax status is not relevant to the purpose of the provision

A non-resident corporation (“US Corp”) sold trademarks at a sales price in excess of their adjusted cost base to a non-arm’s length Canadian...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.