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The definition of "exempt contribution" provides that the exempt contribution amount will be nil if there were two "survivors" receiving a TFSA payment – but s. ... In the event that the aggregate amount that both survivors attempt to designate as an exempt contribution exceeds the maximum amount allowed, additional information may be required from either or both of the survivors in order for a reasonable designation to be allowed … [including] the conditions specified in the will …. ...

CRA responded: [O]ur long standing position [is] that a shareholder benefit arises under subsection 15(1) … when a corporation pays the life insurance premiums on a policy pursuant to which the shareholder or a person related to that shareholder is the beneficiary of the policy. The amount of the benefit to be included in computing the shareholder’s income in a given taxation year is usually equal to the amount of the insurance premiums paid by the corporation for that year. … Accordingly, given that a segregated fund policy is, by definition, a life insurance policy, we cannot confirm that no benefit arises in the described situation …. The question of whether a benefit under subsection 15(1) … has been conferred is generally one of fact to be determined on a case-by-case basis. ...

5 May 2021 IFA Roundtable Q. 4, 2021-0887601C6- 2021 IFA Q4- section 247 Post Cameco-- summary under Paragraph 247(2)(a) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2)- Paragraph 247(2)(a) Cameco may limit the use of s. 247(2)(d) recharacterization – and acknowledges that s. 247(2)(c) must take into account a relationship’s circumstances Regarding the CRA response to the TCC and FCA decisions in Cameco, CRA stated “that these decisions may limit situations where the re-characterization provision in paragraphs 247(2)(b) and (d) could be applied … [h]owever, the CRA will continue to consider the application of the re-characterization provision where appropriate.” CRA further stated: The CRA will continue to administer … 247(2)(a) and (c) in a manner consistent with the guidance … [in] General Electric [para. 54]: “…The task in any given case is to ascertain the price that would have been paid in the same circumstances if the parties had been dealing at arm’s length. ...

Consequently … upon Mr. X's death, subsection 70(5) would apply …. ...

CRA went on to indicate that where “the person on whom the benefit has been conferred is both a shareholder and an employee … a determination will have to be made … as to whether the benefit was conferred by the corporation on the person as a shareholder or as an employee.” ...

CRA noted that since the number of substituted properties on hand at the end of the period beginning 30 days before and ending 30 days after the disposition of the shares to the taxpayer or an affiliated person was greater than at the time of the disposition, the formula (Deemed nil loss = (the lesser of S, P and B) / S x L) referred to in some CRA positions was inapplicable (i.e., the full $10,000 loss was denied). ...

CRA noted that since the number of substituted properties on hand at the end of the period beginning 30 days before and ending 30 days after the disposition of the shares to the taxpayer or an affiliated person was greater than at the time of the disposition, the formula (Deemed nil loss = (the lesser of S, P and B) / S x L) referred to in some CRA positions was inapplicable (i.e., the full $10,000 loss was denied). ...

Paragraph 304(3)(a) … would deem the child to be the holder of the contract and, as such, would meet the requirements of clause 304(1)(c)(iii)(A) …. In our view, the expression "in trust" in paragraph 304(3)(a) … is more akin to a nominee and is not meant to include a trust not specifically referenced in clause 304(1)(c)(iii)(A), namely those identified in (ii) to (iv) above. ...

CRA responded: [O]n the limited basis of the facts submitted … it would be reasonable to consider that the business that generated the losses, namely the management services business that was carried on by Holdco prior to the acquisition of control and prior to the amalgamation of Holdco and Opco, ceased to be operated after the amalgamation. This conclusion is based in particular on … the management activities performed by the Amalco employee [being] intended solely to support the corporation in the manufacturing field, and … not in themselves represent[ing] the carrying on of a business. … [C]reating two divisions with a separate financial statement for the management services and manufacturing businesses would not change our conclusion … that it would be reasonable to consider that the management services business that was carried on by Holdco ceased to be carried on after the amalgamation of Holdco and Opco. ...

. … [T]he CRA policy is not at odds with the decision in … Béarence. CRA officials are expected to be reasonable in their requests for the information and documentation. ...