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However, Art. 10(7) denied Treaty benefits to a resident if “one of the main purposes of any person concerned with … [a] transfer of the shares … or with the establishment … of the person that is the beneficial owner of the dividend, is for the resident to obtain the benefits of this Article.” ...

In the situation where FA1 was required to compute its income (pursuant to Reg. 5907(1) – earnings – (a)(iii)) under Part I of the Act, CRA indicated that the interest was deductible under s. 20(1)(c) “because the borrowed funds replaced capital that…had been used by FA1 for the purpose of earning income from an active business,” whereas in the situation where the earnings were computed pursuant to (a)(i) or (iii) of the earnings definition under local tax law and the interest was non-deductible under such law, CRA simply stated that the interest would be deductible under Reg. 5907(2)(j). ...

X satisfied the active engagement condition with respect to Opco’s business, and further finding that if “Holdco will pay the Dividend to Child X out of the funds from the $100,000 dividend received from Opco or from any dividends previously received from Opco, then … the Dividend would thus have come, directly or indirectly, from a related business- that of Opco- in respect of Child X.” so that the Dividend would be added to the split income of Child X, unless it constituted an excluded amount by virtue of another exclusion, CRA then stated: [I]f it can be determined that Holdco will pay the Dividend to Child X out of its after-tax income from its stock market investments, then that dividend would be an excluded amount for Child X and would not be included in calculating the child’s split income. ... On the other hand, if it were determined that Holdco does not carry on a business, then the Dividend would also be an "excluded amount" in respect of Child X by virtue of subparagraph (e)(i) of the definition … [since] there must be … a business carried on by an entity. … Based on the foregoing, Holdco must adequately monitor its funds derived from stock market investments in order to determine whether those funds were used to pay the Dividend. ...

CRA responded: [Under] paragraph (a) … of "excluded property" … [t]here must in particular be income from its business, rather than more generally "income from an active business" as that term is defined in subsection 95(1). … [T]he following should be considered in particular: the use that is actually made of the property in the course of the various activities of the FA, the income from the use or possession of the property, the intention of the FA with respect to the use and holding of the property, the terms and conditions of ownership of the property, the nature of the activities of the FA and current practices in the particular industrial sector. ...

The above comments should be considered whenever there is a conversion … to U.S. limited liability partnerships or U.S. limited liability limited partnerships…. … The CRA remains open to … an advance income tax ruling request…. ...

(c) of the definition of “excluded entity” in s. 18.2 is that “all or substantially all of the businesses … and undertakings and activities of the taxpayer are … carried on in Canada.” ... In this scenario – where Canada maintains full ability to tax – are the businesses, undertakings and activities of B Co carried on in Canada? ...

The Trust and its beneficiaries then used their sales proceeds to subscribe for the shares of a newly-incorporated holding company (Holdco): Trust – 50% of the Holdco shares; Mr. and Mrs. X – 20% each; and Child X and Y – 5% each). Holdco generated $150,000 from investing these funds in the stock market and paid a $100,000 dividend pro rata to its shareholders, so that Child Y received a $5,000 dividend. ...

The beneficiaries then used their sales proceeds to subscribe for the shares of a newly-incorporated holding company (Holdco): Trust – 50% of the Holdco shares; Mr. and Mrs. X – 20% each; and Child X and Y – 5% each). Holdco generated $150,000 from investing these funds in the stock market and paid a $100,000 dividend pro rata to its shareholders. ...

During the review period, the CRA continues to administer employee discounts on merchandise in accordance with the administrative policy outlined in Guide T4130, Employers Guide – Taxable Benefits and Allowances …. ...

. … In the example submitted, the CRA would not consider a Class A share … to be identical to a Class B share …. ...