Example

Assume that throughout the year, Canco in the above example has $1,000 in paid-up capital and no other equity, and owes $1,000 to US-Co (its parent) bearing interest at 7% (paid as to $35 at the end of each of Q2 and Q4), and owes $1,000 to UK-Co (a sister) bearing interest at 5% ($25 at the end of Q2 and Q4).

$500 (or 25%) of this debt exceeds the thin capitalization limit of 1.5-to-1. Accordingly, 25% of each of the above interest payments would be deemed to be a dividend absent a designation under s. 214(16)(b). If Canco instead designates $17.50 of its fourth quarter US-Co interest payment to be a dividend (i.e., 25% of total US-Co interest of $70), and $12.50 of its fourth quarter UK-Co interest payment to be a dividend (25% of $50), the imposition of Part XIII tax will be deferred to the end of Q4.

Mr. X bought a Bitcoin on June 1, 2013 for $100. Mr. X then sold the Bitcoin on December 1, 2013 for $500. Based on his particular facts and circumstances, Mr. X determined that the gain was on account of capital. Mr. X has a capital gain...[of] $400 ($500 less $100).

…Ms. B buys a book from the bookstore using Bitcoins. The value of the book is $20. Mr. A [the vendor] would treat the transaction as if he had been paid $20 in Canadian dollars for the book.