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X sells all the shares of Holdco, which holds all the shares of Opco 1 and Opco 2, to Buyco, which is at arm's length. He grants a non-compete covenant to Buyco respecting the business of each of Opco 1 and 2. ...

LLC provides for the manager to receive incentive compensation in the form of a 2% income allocation for management, and a 20% profit share in certain circumstances. ... Would there be 3 classes of equity interests, the first providing for the 2% income allocation, the second for the 20% incentive allocation, and the third for the residual amounts? ... Thirdly, if the income is to be allocated based on, for example, the revenue or net income for the year, between 2 owners say, A and B, would each of A and B have a distinct equity interest, where the value of these equity interests may change from year to year (like 2 separate classes of common shares) – and, if so. is there a disposition when the equity interests change? ...

However, that case proceeded under the informal procedure and on that basis, the CRA is not bound by that decision. 2. ... Respecting the voluntary disclosure program, CRA stated (TaxInterpretations translation): Each disclosure must satisfy these four conditions: 1. is voluntary, 2. is complete, 3. engages the imposition or potential imposition of a penalty, and 4. comprises information that is more than a year overdue. ...

X sells all the shares of Holdco, which holds all the shares of Opco 1 and Opco 2, to Buyco, which is at arm's length. He grants a non-compete and non-solicitation covenant to Buyco respecting the business of each of Opco 1 and 2. ...

Situation 2. Same situation as above, but this time only one of the children lives in the residence. ... CRA indicated that if the only persons beneficially interested (as defined in s. 248(25)) in the trust are those listed in the above descriptions the specified beneficiaries would be: in Situation 1, the parents. in Situation 2, the parents and the child who ordinarily inhabited the residence. in Situation 3, the child who ordinarily inhabited the residence. ...

Situations 2 and 3 are the same except that the $15,000 and $5,000 had been held by him in two separate TFSAs at two Canadian financial institutions (Situation 2) or at one such institution (Situation 3). ... Would the answers for Situations 2 and 3 change on the basis that there were two separate "arrangements," so that no exercise of CRA discretion was required? ...

Accordingly, a deduction can be made during years 1, 2 or 3 of a GRE for gifts made in years 4 and 5 of an estate which would be a GRE but for the passage of 36 months. ... (b) If this is not the case, does this mean that the gift made in year 4 or 5 by an estate which would have been a GRE but for the passage of 36 months cannot benefit from the deduction in years 1, 2 or 3 of the GRE? ... However, the eligible amount of a gift cannot be included in the "total charitable gifts" of an estate for a preceding taxation year of the estate, namely, for years 1, 2 and 3 in your example. ...

5 October 2012 Roundtable, 2012-0451271C6 F- Residence of a trust-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) trust residency determination focuses on where in fact there is the exercise of authority over significant decisions Following Fundy Settlement, what weight should be assigned to the following criteria in determining the residence of a trust that holds portfolio investments? 1- The location of the brokerage account 2- The location of the portfolio manager 3- The fact that the management is or is not discretionary 4- The place where the securities are held 5- The location of trustees’ meetings and decision making After noting that Fundy Settlement found “that it is justified to apply the central management and control test in determining the residence of a trust, just as it is applied in determining the residence of a corporation,” CRA stated: [I]t does not seem appropriate to define and comment on any specific factors that may be relevant for the purpose of determining whether there in fact is an exercising of authority over significant decisions of a trust. ...

On March 31 of Year 3, 4 and 5 the individual’s performance for Year 2, 3 and 4 is determined and the amount is revised as of December 31 of Year 2, 3 and 4, respectively. ...

2. What if the shareholder has more than one borrowing from the same creditor, where the corporate assets secure all of the loans? ... …[W]here a financial institution lends money on commercial terms to an individual that is a shareholder of a corporation, the corporation provides a security interest in its property to the lender, and such property can only be used in the event of default on the loan as a means of repaying amounts owing by the debtor under the lending agreement, then the security interest would not ordinarily be considered a “specified right”. 2. ...