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Brief summary of oral response No – it’s applied on the property ensemble. ... For details on this subject, please see “Estate Donations- Deaths after 2015", Questions / Answers [http://www.cra-arc.gc.ca/gncy/bdgt/2014/qa14-eng.html] and "Estate Donations by Former Graduated Rate Estates", Questions / Answers, that are available on the website of the CRA. ... If the CRA considered that the dividend of $35,000 declared on the Class "A" shares in the capital stock of Opco was part of the FMV of the Class "A shares immediately before the dividend payment, the hypothetical FMV of the Class "A" shares held by HA is $80,100 ([($170,300- $35,000) / 3] + $35,000). ...

If that situation were to come up (and I don’t recall that it has) we might conclude that, even though someone might suggest that the very fact that we drafted specific limitations on loss carryforwards and this was a way of extending the carry-forward of losses, this might not be an occasion justifying using our resources to challenge taxpayers. ... There was this view that we were legislating by press-release – every fortnight, we were dealing with something else. ... Reading the Wild case, it seems inconsistent with the expressed intention of Parliament – but I also appreciate the legislative concern that the decision identified. ...

There is a team working flat-out on this project, with additional resources having been pulled in. ... However, we identified a number of issues – some of which were not borne out by the data and have been dropped. ... The Greenhouse Gas Pollution Pricing Act – famously “not a tax” – has a preamble. ...

Further, the settlor /grantor can exercise his / her power to revoke the trust at any time. The settled property often includes all personal, tangible, intangible and real property of the settlor / grantor. ... Subsection 159(6.1) election: In external interpretation 2015-0594201E5 we were asked whether an election pursuant to subsection 159(6.1) of the Act can be made where a liability for tax arises from a deemed disposition of resource property. ...

Similarly, the definition of "principal residence" in section 54 states that it is a residence “owned, whether jointly with another person or otherwise, … by the taxpayer”. ... These include capital property, resource property, inventory and certain other property specifically mentioned. ...