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2 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 20, ¶1071)-- summary under Subsection 48(3) Summary Under Tax Topics- Income Tax Act- Section 48- Subsection 48(3) Where a person holds a capital interest in a trust at the time of becoming a resident of Canada, the ACB of that interest is its fair market value at the time he became a resident. ...

2 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 11, ¶1049)-- summary under Paragraph 113(1)(a) Summary Under Tax Topics- Income Tax Act- Section 113- Subsection 113(1)- Paragraph 113(1)(a) Interest paid by U.S. subsidiary which is recharacterized as a dividend for U.S. purposes will be taxed as interest income in the hands of the Canadian parent. ...

2 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 14, ¶1080)-- summary under Subsection 74.4(2) Summary Under Tax Topics- Income Tax Act- Section 74.4- Subsection 74.4(2) The purpose test in s. 74.4(2) must be applied separately to each transfer of property, with the result that imputed income on a transfer which does not meet the purpose test effectively cannot be off-set by excess income received as the result of a transfer of property that does not violate the purpose test. ...

2 November 2023 APFF Roundtable Q. 2, 2023-0982751C6- Meaning of purpose tests in paragraph 55(2.1)-- summary under Paragraph 55(2.1)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) the payment of a pre-closing dividend of significant excluded assets by the target to its parent likely would engage s. 55(2) where no safe income A corporation resident in Canada ("Parent") owning 100% of "Target" accepts an offer from an unrelated third party ("Purchaser") to purchase all of the Target shares for $3 million, with the sale agreement specifying that assets which Purchaser does not wish to acquire ("Excluded Assets") are assigned a value of zero. ...

15 May 2019 IFA Roundtable Q. 2, 2019-0798751C6- Shared workspaces and PE-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 a Canadian shared-work space can readily constitute a PE In the following examples, will a U.S. resident carrying on business in Canada, be considered to be a permanent establishment (“PE”) in Canada, assuming Arts. ... Example 2 The fact that another entity owns the shared workspace is not important to the PE analysis – it is enough that the shared workspace is at the non-resident’s disposal. ...

Situation 1 – If Individual A had designated three siblings as equal beneficiaries under the FHSA in accordance with provincial law, would each sibling be required to report $10,000 in Year 2? Situation 2 – If Individual A’s estate had been designated as beneficiary under the FHSA in accordance with provincial law, would it be required to report $30,000 in Year 2? ... CRA then indicated that, on the assumption that, under the provincial law, the beneficiaries under the FHSA were the siblings in Situation 1, and the estate in Situations 2 and 3, there would be an inclusion in such beneficiaries’ income pursuant to s. 146.6(17)(c). ...

31 July 2003 Ruling Case No. 37807-- summary under Section 2 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part IV- Section 2 Supplies to the residents of a retirement home did not qualify under s. 2 of Part IV of Schedule V. ...

2 October 1996 T.I. 961781 (C.T.O. "Thin Capitalization Back-to-Back Loans")-- summary under Subsection 18(6) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(6) S.18(6) will not be applied to a second loan made by a corporation resident in Canada ("Canco 1") to a second Canadian-resident corporation ("Canco 2") provided that: the person who made the first loan to Canco 1 is a specified non-resident shareholder of Canco 1 and qualifies as a specified shareholder of Canco 1 otherwise then by virtue of a right referred to in paragraphs (c) or (d) of the definition of specified shareholder in s. 18(5); the first loan and the second loan bear the same rate of interest; and Canco 1 is related to Canco 2. ...

In Scenario 2, Investco acquires 100 common shares of Pubco on February 1. 201X and a further 50 shares on February 15, 201X. ... Scenario 3 is the same as Scenario 2 except that the final disposition is of 25 shares. ... Respecting Scenario 2, for the same reasons, the $100 loss of Portco was not denied. ...

CRA stated: if a distribution from a Canadian-resident trust would otherwise be included in the Norwegian resident’s taxable income, but the recipient itself is, under Norwegian tax law, exempt from the imposition of income taxation, we would consider that the “income is taxable” for the purpose of paragraph 2 of Article 22. In contrast, if the distribution were made to a Norwegian resident that was otherwise taxable under Norwegian tax law but entitled under Norwegian tax law to exclude the distribution from income, the requirements of paragraph 2 would not be met. ... As a result, paragraph 2 of Article 22 of the Treaty would apply to lower the withholding rate on the Taxable Distributions to 15%. ...