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[fn 70: … 2012-0462941C6 …. This circularity problem was identified by Nick Moraitis and Manu Kakkar, in "Potential Circularity Problem with Estate Loss Carryback" (2006) 6:3 Tax far the Owner-Manager 6-7.] ...

[F.n. 275 … IT-286R2.] … The CRA accepts that an amount may be deductible to the trust when the amount is determined by a formula and is not calculated until the preparation of the trust's tax return after the end of the applicable year. ...

Govindadeva Bernier, Tim Scholz, "Income Sprinkling Using Private Corporations", Office of the Parliamentary Budget Officer (with thanks to “Finance Canada officials for their helpful technical discussions”), 8 March 2018-- summary under Paragraph (b) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Reasonable Return- Paragraph (b) Preferred scenario assumes that all spouses aged over 24 are earning a reasonable return (pp. 1-2) The Parliamentary Budget Officer (PBO) … computed possible revenue outcomes for the government based on three different scenarios. ... This is our preferred scenario. … ...

Holdco is not … a small business corporation. One of the main purposes of the transaction is to reduce the income of Mr. ... X then exchanges his $15 million of class A preferred shares of Holdco for $3 million of class B preferred shares of Holdco pursuant to section 86 ("the second transfer ")…. ...

Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper-- summary under Paragraph 212.3(1)(b) Summary Under Tax Topics- Income Tax Act- Section 212.3- Subsection 212.3(1)- Paragraph 212.3(1)(b) No s. 245(4) abuse where use of a Canadian GP to avoid FAD rules (pp. 15, 16) [T]he purpose of the FAD rules is to deter foreign multi-nationals from … benefiting economically by stuffing non-Canadian operating companies under Canada in circumstances where it otherwise would make little or no sense to do so. That harm is quite distant from a PE fund looking to buy a Canadian-owned or public Canadian multinational and then continue to run the business. … [T]here are [thus] good policy reasons why the FAD rules should not apply to PE funds that are direct owners of Canadian portfolio companies. ...

See … 2006-0196031C6 ….] ...

[fn 47: … 2015-062451117 … [and] 2012-0444091C6] The result may be different if a partnership’s partners made loans to Projectco directly (or through a parallel structure) rather than through the non-Canadian partnership being tested. ...

Kirby, "Vendor Planning for Private Corporations: Select Issues", 2017 Conference Report, (Canadian Tax Foundation), 11:1-28-- summary under Subsection 129(1) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(1) Potential generation of dividend refund with s. 84.1(1) dividend (p. 11:23) [T] he 2002 technical interpretation discussed above … stated that the technical requirements for triggering a refund of RDTPH are not met when the dividend is deemed to have been paid pursuant to section 84.1… It may be credibly argued that the only sensible result is that a deemed dividend arising under section 84.1 should give rise to the recovery of RDTOH because a dividend cannot be paid except on a class of shares, because the person receiving a dividend is a shareholder, and because the right to receive dividends is attached to a share…. The individual will own shares of Newco when the dividend arises, and therefore it could be argued that the deemed dividend under section 84.1 should be considered to be paid on these shares. … In common parlance, a “dividend” is considered to be a distribution of corporate profits to its shareholders, and therefore it could be argued that in order for a deemed or fictitious dividend to arise, there must be deemed or fictitious shares on which the dividend is paid. ...

CRA position on interpretation of “interest” in s. 188.1(3.2) [A]nother idea … is for the corporation to redeem the shares with the compensation being a promissory note. ... In a technical interpretation … the CRA takes [that] interpretation. ...

. … [B]ecause none of the Cancos have a qualifying interest in Forco 2, the recharacterization rule in clause 95(2)(a)(ii)(B), for example, would not be available since each Canco would hold less than 10 percent of Forco 2 on a lookthrough basis. ... In that case, the recharacterization rule in clause 95(2)(a)(ii)(B) may apply …. ...