Principal Issues: Can losses and ITCs of a subsidiary be claimed by a parent on a winding-up as a result of a two-step loss acquisition where the loss business carried on by the subsidiary and the shares of the subsidiary are acquired in separate transactions.
Principal Issues: 1. Does non-eligible medical expense tax credit coverage under a plan need to meet any specific criteria? 2. If a plan meets the new PHSP criteria, are employer contributions to the plan excluded from the employee’s income? 3. If an employer has a number of plans under their group benefits program, can the plans be combined for purposes of determining PHSP eligibility?
Principal Issues: (1) Whether a partnership is deemed to have received a dividend under subsection 84(3) when shares of a corporation are cancelled for no consideration. (2) Whether a partnership is entitled to deduct an amount by virtue of paragraph 28(1)(f) in the computation of its income.
Position: (1) No. (2) Yes.
Reasons: (1) Application of the Act. (2) Application of the Act.