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. … [T]o conclude that any such obligation constitutes a commercial debt obligation, one must conclude that interest would be deductible if it were payable on the obligation. ... Although an argument could be made, depending on the precise facts, that any such interest may be deductible under section 9,…if a taxpayer is seeking to deduct any claims for damages, the CRA will likely argue strenuously that if the deduction of those claims is allowed, then their settlement should also be subject to the application of the debt forgiveness rules. … ...

", Tax For The Owner Manager, Vol. 16, No. 4, October 2016, p. 3-- summary under Subsection 152(9) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(9) S. 152(9) targets Last The court's finding in Last and in the earlier cases on which Last was based – that the prohibition of an increased assessment on appeal is to be applied on a source-by-source basis – is arguably inconsistent with other case law concerning what an assessment is (the assertion of the amount of tax owing). ...

. … [A]ccording to [9634245], it is not possible to specify an amount in foreign currency. … [T]his interpretation is arguably inconsistent with the tax policy underlying subsections 191(4) and (5)… [and] with [CRA's] position regarding the application of section 51.1.... ...

[fn 73: … 2011-0414731E5 …] Assuming that the CRAs interpretation is correct, subsections 112(3) to (7) would not apply in respect of a capital dividend that is deemed to be paid under paragraph 84.1(1)(b). 50% solution addressing s. 112(3.2) (p. 143) [i]t many be preferable to redeem shares owned by an estate through a combination of capital dividends and taxable dividends pursuant to the so-called 50 percent solution strategy. ...

. … An election under subsection 107(2.002) may thus ensure that the beneficiary acquires the distributed property at a higher adjusted cost base, with the result that capital gains or income accrued by the non-resident trust before the distribution is not subject to tax in Canada on a subsequent disposition of the distributed property by a Canadian-resident beneficiary. ... [fn 93: See… 2015-0582701E5 …and… 2004-0062121E5] Accordingly, in many circumstances it may be more efficient, subject to applicable foreign tax considerations, for a non-resident trust to realize an actual disposition of the property before the distribution. … The sole purpose of the election is to enable the beneficiary to acquire the distributed property at a cost equal to its fair market value,…[T]his purpose can be achieved in a variety of other ways, such as an actual disposition of the property (for example, a transfer to a wholly owned subsidiary of the trust) before the distribution, or even a sale of the property to the beneficiary in consideration for a promissory note, which is subsequently set off against a capital distribution made by the trust to the beneficiary. ...

If the UWA has the UWs acquire the FTS and then sell them to the intended subscribers, … the initial subscriber is the UW and the intended subscribers are subsequent purchasers who are not technically entitled to any renunciations. ... No need to contractually preclude general common law right to sue (p. 12:23) Most provinces have certain statutory rights of rescission. … All subscription agreements will generally have a covenant that the PBC will indemnify FTS holders if the tax deductions promised are not delivered. ...

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 Subsection 120.4(3) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(3) 95% of additional federal tax to be collected from families with taxable income over $150,000 The Parliamentary Budget Officer (PBO) … computed possible revenue outcomes for the government based on three different scenarios. ... This is our preferred scenario. … Under scenario 1, PBO’s preferred scenario, the new policy changes would result in an estimated $589-million increase in taxation revenues [for 2018-19], $356 million or 60 per cent of which would go to the federal government. ...

It might seem that subsection 55(2) will not apply because the dividends are less than the safe income ($250 < $300), but this is not the case. For the old shares, Holdco has $200 of safe income (100 x ($1 + $1)) and $125 of dividends (100 x $1.25). ...

Dov Begun, "Equity Based Compensation and Stock Options", 2017 Annual CTF Conference draft paper-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) Need to avoid constructive receipt under a phantom plan (p. 4) The CRA … interprets the word “received” in the ITA as referring to amounts constructively received as well as actually received…. [1984 CTF Roundtable, Q.13]... ... [fn 10: 2014-0535951E5]… DSU plans may also be structured to provide for dividend equivalents in the same manner as described above for RSUs. … As the stock price approaches the peak of the cycle, DSUs might actually provide an incentive for top executives to leave as it is only on employment termination that the value of the DSUs can be realized. ...

. … [T]he optimal structure … involves AII being earned by a C corporation that is a CFA of a CCPC. ...