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18 March 2003 External T.I. 2003-0002915 F- Subsections 40(3.3) & 40(3.4)-- summary under Subsection 40(3.4) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.4) taxpayer can designate order of disposition On December 16, 2002, Holdco sold 200 of its 1,000 common shares of a public corporation to an unaffiliated person $1,500, realizing a capital loss of $500, and less than 10 days after December 16, 2002, Holdco acquired 200 new common shares of the public corporation at a cost of $1,500. ...

2012 Ruling 2010-0355941R3- reverse subsidiary merger- 87(1) & 87(11)-- summary under Subsection 87(11) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(11) survivor style amalgamation on Code reverse triangular merger Under a BC plan of arrangement, a BC corporation ("SubcoTarget") is merged with its wholly-owned BC subsidiary ("Target") to form "Amalco" with the same effect as if they had amalgamated under section 269 of the Business Corporations Act (BC), except that the legal existence of Target does not cease and it survives the merger, Subco ceases to exist and the property of Subco (other than its shares of Target, which are cancelled) become the property of Target. ...

2012 Ruling 2010-0355941R3- reverse subsidiary merger- 87(1) & 87(11)-- summary under Subsection 87(1) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(1) reverse triangular "E" merger- survivor style amalgamation Under a BC plan of arrangement, a BC corporation ("SubcoTarget") is merged with its wholly-owned BC subsidiary ("Target") to form "Amalco" with the same effect as if they had amalgamated under section 269 of the Business Corporations Act (BC), except that the legal existence of Target does not cease and it survives the merger, Subco ceases to exist and the property of Subco (other than its shares of Target, which are cancelled) become the property of Target. ...

2011 Ruling 2011-0416891R3- Fees for Digital Content & Management Services-- summary under Paragraph 212(4)(a) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(4)- Paragraph 212(4)(a) management of on-line store A US LLC ("Corporation C"), whose sole member was a US corporation qualifying for benefits under the Canada-US Convention, ran a platform for the provision of "Digital Content" (movies, television shows, music videos, documentaries and similar audio-visual content) which it (and affiliated corporations) were permitted to distribute under content licence agreements with the third-party holders of the copyright. ...

2011 Ruling 2011-0416891R3- Fees for Digital Content & Management Services-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 A US LLC ("Corporation C"), whose sole member was a US corporation qualifying for benefits under the Canada-US Convention, ran a platform for the provision of "Digital Content" (movies, television shows, music videos, documentaries and similar audio-visual content) which it (and affiliated corporations) were permitted to distribute under content licence agreements with the third-party holders of the copyright. ...

28 November 2010 CTF Roundtable, 2013-0487431C6- Value of Vote-Only Shares – 2010 CTF Conference-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares premium for voting rights The questioner referenced the CRA statement at the 2009 British Columbia Tax Conference that, in the context of an estate freeze of a Canadian-controlled private corporation, where the freezor, as part of the estate freeze, keeps controlling non-participating preference shares in order to protect his economic interest in the corporation, CRA generally accepts that no premium should be attributed to such shares in determining their fair market value under s. 70(5), and asked whether this position also applies for the purposes of s. 104(4)(a), e.g., re the deemed disposition arising on the death of the spouse who is the beneficiary of a spousal trust. ...

2 July 2013 External T.I. 2012-0454251E5- 149(1)(l) – donations to capital fund-- summary under Paragraph 149(1)(l) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(l) sale of naming rights Generally, an organization referred to under s. 149(1)(l) will not lose its s. 149(1)(l) exemption for collecting donations from members or from businesses affiliated with its members for use in a capital project that furthers the organization's non-profit purposes, nor will it lose its exemption for maintaining a "wall of honor," naming rights, or similar systems for recognizing such contributions, providing that such recognition has only nominal value. ...

4 December 2013 External T.I. 2012-0465891E5 F- Primes d'assurance / Premiums-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) sub plan with only one employee of particular employer could be a group plan if benefits similar to those for employees in other sub plans The employees of Corporation A were members of four basic insurance plans respecting health insurance, salary insurance and accidental death and dismemberment insurance available to employees of employers in a particular industry. ...

28 May 2015 IFA Roundtable Q. 5, 2015-0581531C6- IFA 2015 Q.5: "Causality test" in 18(6) & 212(3.1)-- summary under Paragraph 18(6)(c) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(6)- Paragraph 18(6)(c) "because of" causality test What is the requisite degree of linkage referenced by the "because" test in clause (B) of ss.18(6)(c)(i), 18(6)(c)(ii), 212(3.1)(c)(i) and 212(3.1)(c)(ii) (the "Clause B causality tests") between a debt owing by the taxpayer to a creditor and a secondary obligation existing between that creditor (or someone not dealing at arm's length with that creditor) and certain non-residents, so as to engage s. 18(6.1) or 212(3.2)? ...

16 June 2014 STEP Roundtable, 2014-0523091C6- STEP CRA Roundtable – June 2014-- summary under Subsection 70(6) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6) bequests to both spouse and common law spouse Can s. 70(6) apply to a transfer by a taxpayer both to his or her spouse and a transfer to his or her common law spouse? ...