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Hersh Joshi, Jack Silverson, "Understanding and Doing Business with Tax-Exempt Entities", 2018 Conference Report (Canadian Tax Foundation), 29:1 – 35-- summary under Clause 149(1)(o.2)(ii)(C) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(ii)- Clause 149(1)(o.2)(ii)(C) Limitations on borrowing (pp. 29:20-21) [B]orrowing to fund a tenant inducement payment… should generally satisfy the borrowing restrictions, since the purpose of the borrowing is to earn rental income from the real property being leased. ... The real estate corporation can use this borrowed money for the purpose of earning income from real property. … At a subsequent date, the internal financing can be refinanced by having the real estate corporation borrow from an arm’s-length lender and repay the internal financing. ...

Carrie Smit, "Thin Capitalization Amendments – Denied Interest May be Subject to Withholding Tax", CCH, Tax Topics, No. 2114, September 13, 2012, at p. 3.-- summary under Paragraph 214(16)(a) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(16)- Paragraph 214(16)(a) It should be considered whether loans may be transferred among lenders prior to a particular interest payment (or prior to year end in the case of accrued and unpaid interest), in order to access a lower rate of withholding tax. ... Turning to the extension of the thin capitalization rules to debts owing by partnerships: … a Canadian corporate member of a partnership will be deemed to owe its proportionate share of all partnership debt, and the thin capitalization rules will apply to the extent that such debt is owed to a specified lender in respect of the corporation. ...

Jim Kahane, Uros Karadzic, Simon Létourneau-Laroche, "A Fresh Look at Retirement Compensation Arrangement: A Flexible Vehicle for Retirement Planning", Canadian Tax Journal (2013) 61:2, 479 – 502.-- summary under Refundable Tax Summary Under Tax Topics- Income Tax Act- Section 207.5- Subsection 207.5(1)- Refundable Tax Refund mechanics (p. 485) When the employer makes a contribution to an RCA, one-half of the contribution must be remitted to the CRA [fn 22: Subsection 207.5(1), the definition of "refundable tax," paragraph (a).] and placed in a refundable tax account (RTA). ... [fn 24: … paragraph (c).] In the event of termination of the plan, the assets in the RTA are refunded to the RCA. ...

Jim Kahane, Uros Karadzic, Simon Létourneau-Laroche, "A Fresh Look at Retirement Compensation Arrangement: A Flexible Vehicle for Retirement Planning", Canadian Tax Journal (2013) 61:2, 479 – 502.-- summary under Subsection 6804(6) Summary Under Tax Topics- Income Tax Regulations- Regulation 6804- Subsection 6804(6) Resident contribution rule (p. 491) Under these rules, if a newcomer to Canada remains a member of his or her home-country pension plan for more than five years, the foreign pension plan may still be considered an RCA for Canadian tax purposes. ... [fn 63: Subsection 32.1(1)] … ...

Michael Goldberg, "Not Quite Chicken Soup – Part II: Are Powers to Add and Remove Beneficiaries Safe for Canadian Family Trust Precedents", Tax Topics, Number 2175, November 14, 2013, p.1.-- summary under Subsection 248(25) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(25) Effect of power to add and remove beneficiaries (PARB) (p. 2) Does the inclusion of a PARB mean that pursuant to paragraph (1) of this definition everyone in the world would become beneficially interested in the trust? ... Ben Stiller, 2001.] could be seen to have any "right … as a beneficiary under a trust" just because of the inclusion of such a clause. ...

Xiao, "The 88(1)(d) Bump – An Update", 2013 Conference Report (Canadian Tax Foundation), pp.13:1-60-- summary under Subparagraph 88(1)(c.3)(i) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c.3)- Subparagraph 88(1)(c.3)(i) 10% attributable property test applied only during the series of transactions (p. 13:12-13) [W]hen read in a textual, contextual and purposive manner, it would be reasonable to construe the "at any time" wording of the 10 percent test such that the test should not be affected by transactions or events that are not considered part of the series. This construction seems reasonable as a matter of statutory interpretation, and in that respect the absence of an overt series rule in subparagraph 88(l)(c.3)(i) should not be considered to imply otherwise. … [I]t is for the purpose of determining whether a person has acquired substituted property that subparagraph 88(l)(c.3)(i) extends the meaning of the concept of substituted property contained in subparagraph 88(l)(c)(vi). ...

", GST & Commodity Tax, Vol. XII, No. 6, July/August 1998, p. 45.-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership ...

Hybrid Financing – A Canadian Perspective on the U.S. Debt-Equity Regs", 26 September 2016, p. 1151-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) Description of financing by U.S. lender of Canadian real estate company (Canadian RealCo) through hybrid debt (pp. 1158-1159) [I]nstead of [the U.S. taxpayer] investing in shares of the Canadian RealCo, a debt structure may be created that has the economics of a share investment. … The U.S. taxpayer may lend funds to the Canadian RealCo at a reasonable rate of interest. ...

Flannigan, "The Legal Construction of Rights of First Refusal", The Canadian Bar Review, Vol. 76, Nos. 1 & 2, March- June 1997, p. 1.-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) ...

", GST & Commodity Tax, Vol. XVII, No. 5, June 2003, p. 37.-- summary under Subsection 272.1(7) Summary Under Tax Topics- Excise Tax Act- Section 272.1- Subsection 272.1(7) ...