The Meaning of “Control”, “Arms’ Length” and “Related” in the Income Tax Act - Available Early April
This webinar follows and expands on an earlier webinar entitled “Association Rules in the Income Tax Act: Scope and Implications” which aired February 4, 2020
Whether two persons are related, or whether one person is viewed as controlling another can trigger a number of special rules mostly geared toward limiting tax benefits otherwise available to private entities. There are also situations that require parties to transact as though they were at arms’ length and deeming rules to ensure that result. These are relationships that can catch practitioners unaware if they are not familiar with all the ways that private corporations (Canadian-Controlled Private Corporations) are evaluated vis-à-vis the way they transact within a corporate group.
Join Vitaly Timokhov of TaxChambers LLP for a thorough analysis of the various forms of control, the concept of “arm’s length”, and the definition of “related” for income tax purposes. The fundamentals of these concepts are built up through the complex legislative provisions and exceptions, as well as being usefully illustrated by relevant CRA rulings and Tax Court cases. Vitaly will also explore the definition of “connected” and its relevance. This webinar is a must for anyone who services private corporate groups.
More specifically, this webinar will cover:
- Transactions between non-arm’s length taxpayers: fundamentals in section 69
- The statutory definition of arm’s length in section 251 – when are parties dealing at arm’s length.
- When taxpayers are related and why it matters?
- Control: what it means.
- De jure control v. de facto control.
- Control, directly or indirectly, in any manner
- Unrelated parties acting in concert: factual determination.
- Part IV tax: tax on assessable dividend received by a private corporation
- Connected corporations for the purposes of Part IV tax.
This webinar will be of most interest to tax practitioners & accountants, practicing independently or in small to medium sized firms, with the focus on tax planning and compliance services for small to mid-sized privately owned enterprises and private clients holding private corporations though trusts and estates.