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Although the terms in which the court [in … R v. Christophe, 2009 ONCJ 586] describes the intent of the 10 percent rule are broad, the court essentially echoes the statement of legislative intent by finding the purpose of the rule to be the diversification of investments and loans, such that risk is not pooled in any one person. … In September 2000, OSFI sent a memo to all members of the Canadian Association of Pension Supervisory Authorities (which included the CRA) stating that OSFI would adopt an interpretation according to which the 10 percent rule needed to be satisfied at the plan level rather than at the level of the individual investment corporation. A similar ruling was given in… 2005-0126841R3 … When it comes to interpreting two statutes with overlapping subject matter, a common-law presumption exists that the statutes should be interpreted in a coherent and consistent manner. … [T]he CRA … confirmed that the 10 percent rule for the purposes of the preamble in subparagraph 149(1)(o.2)(iii) was to be applied at the plan level and not at the corporation level. [fn 76: 2013-050832117] 30% rule (pp. 29:28-29) “[T] he 30 percent rule”) is found in section 11 of the PBSA investment rules, and it provides… 11(1) Subject to subsection (2), the administrator of a plan shall not, directly or indirectly, invest the moneys of the plan in the securities of a corporation to which are attached more than 30 per cent of the votes that may be cast to elect the directors of the corporation. (2) Subsection (1) does not apply in respect of investments in securities of (a) a real estate corporation; (b) a resource corporation; or (c) an investment corporation. … [T]he 30 percent rule applies only to securities to which more than 30 percent of the voting rights to elect directors are attached …. ...

Ken Snider, "Share for Share Exchanges — Subsection 85.1(5) Revisited", International Tax (Wolters Kluwer CCH), No. 114, October 2020, p. 5-- summary under Subsection 85.1(5) Summary Under Tax Topics- Income Tax Act- Section 85.1- Subsection 85.1(5) Potential deeming of shares of non-resident to be taxable Canadian property (TCP) (p.5) Where the Exchanged Foreign Shares are taxable Canadian property ("TCP") to the vendor, the Issued Foreign Shares are deemed to be TCP at any time within 60 months after the exchange. This could arise, for example, if a non-resident is disposing of shares of a non-resident corporation whose sole asset is shares of a Canadian corporation whose principal asset is Canadian real property or a Canadian resource property. ...

Timothy Hughes, Matias Milet, Marc Richardson-Arnould, "Private Equity Funds – Selected Canadian Tax Issues", Tax Management International Journal, 2016, p.84-- summary under Paragraph 115.2(2)(b) Summary Under Tax Topics- Income Tax Act- Section 115.2- Subsection 115.2(2)- Paragraph 115.2(2)(b) Restrictions on s. 115.2 safe harbour (p. 86) The safe harbour contains a number of restrictions. For example, a share in the capital stock of a private portfolio company, or an interest in an unlisted partnership or trust, will not be a "qualified investment" for purposes of the safe harbour where more than half the value of the share or interest is derived from Canadian real estate or resource property. ...

Dean Landry, Colin Mowatt, "The Uncertainty Surrounding Uncertain Tax Treatments", Perspectives on Tax Law & Policy, Vol. 4, No. 3, September 2023, p. 13-- summary under Subsection 237.5(2) Summary Under Tax Topics- Income Tax Act- Section 237.5- Subsection 237.5(2) Background (p. 13) The key definitions in s. 237.5 are modelled on IFRIC 23, which indicates that if the company identifies an uncertain position and concludes it to be “not probable” that the tax authority or the courts will accept the position, it must “reflect” the effect of that uncertainty in its financial statements. ... US experience (p. 14) The US experience, as discussed above, has been that the US “uncertain tax position” (UTP) rules have not provided any new information to tax auditors and appear to result in an unnecessary drain on resources for taxpayers and the IRS. ...