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21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election-- summary under Net Earnings Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(1)- Net Earnings surplus pools are not to be retroactively adjusted for a FACL carryback In 2010, CFA paid the "2010 Dividend" to its 100% parent ("Canco"). ...

27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6- TOSI – Excluded Shares & Related Business-- summary under Excluded Shares Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares exclusion for investment business or passive amounts not derived from a related business 29 May 2018 STEP Roundtable Q.7, 2018-0744031C6 indicated that the shares of a corporation that did not generate business income (e.g., a corporation that generated rents that, given the level of activity, constituted income from property) cannot qualify as excluded shares, whereas in Examples 8 and 12 of the Guidance on the Application of the Split Income Rules for Adults (December 13, 2017), shares of a corporation earning income from passive investment assets qualified as excluded shares. ...

25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6- Curr Use & 95(2)(a)(ii)(B) & (D)-- summary under Subclause 95(2)(a)(ii)(D)(I) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(D)- Subclause 95(2)(a)(ii)(D)(I) acquisition of shares that were not excluded property qualified under current use test FA Finco (a foreign affiliate of Canadian Parent) lends to FA Holdco (a Delaware subsidiary of Canadian Parent), which uses the borrowed money to acquire all of the shares of FA Target, which are not excluded property. ...

25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6- Curr Use & 95(2)(a)(ii)(B) & (D)-- summary under Subclause 95(2)(a)(ii)(D)(III) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(D)- Subclause 95(2)(a)(ii)(D)(III) in light of the current-use test, borrowed money used to acquire shares that were not excluded property could satisfy s. 95(2)(a)(ii)(D) FA Finco (a foreign affiliate of Canadian Parent) lends to FA Holdco (a Delaware subsidiary of Canadian Parent), which uses the borrowed money to acquire all of the shares of FA Target, which are not excluded property. ...

4 March 2025 External T.I. 2025-1053731E5- DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement-- summary under Subsection 87(8.4) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(8.4) the Explanatory Notes on s. 87(8.4) partially conflated it with s. 87(8) The Explanatory Notes to ss. 87(8.4) and (8.5) provide: New subsections 87(8.4) and (8.5) allow taxpayers to elect for dispositions of taxable Canadian property (“TCP”) that is shares of a corporation or an interest in a partnership or trust to occur on a tax-deferred (“rollover”) basis, where the disposition results from a foreign merger that meets certain conditions. ...

18 June 2015 STEP Roundtable Q. 2, 2015-0572091C6- 2015 STEP – Q2 – Meaning of Graduated Rate Estates-- summary under Graduated Rate Estate Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Graduated Rate Estate one estate even if multiple wills (see also summary of initial response at 19 June 2015 STEP Roundtable, oral Q.2(a)) If an estate for a deceased who passed away after 2015 is under administration in its first 36 months, will it be considered a graduated rate estate in its entirety, even if there are two wills. ...

25 November 2012 Roundtable, 2013-0479401C6 F- Employés et Achat Ltée – commentaires panel ARC-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) Buyco that is formed by employer to purchases departing employees’ shares is NAL In order to facilitate the disposition of shares of departing employees who had purchased their shares under an employee share ownership plan (ESOP), Opco forms and injects funds into a new company (Buyco), which uses those funds to purchase the employee’s Opco shares. ... This … is consistent with … 2007-0243171C6, 2002-0166655 and 2004-0103061E5 … Petro-Canada and … RMM …. ...

14 June 2007 Internal T.I. 2007-0229311I7 F- Capital Dividend Account-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt making accounting entries does not constitute payment of a dividend After noting that payment of two back-to-back capital dividends (from “Subco” to “Parentco,” and form it to its individual shareholder) had been accomplished only by accounting entries, the Directorate found that this was insufficient to give rise to a capital dividend “received” by Parentco, so that there had been no addition to its capital dividend account. In this regard, it stated: [T]he mere making of the accounting entries … does not in itself constitute the payment of a dividend … by either Subco or Parentco. … [H]owever … a dividend can be paid by a corporation and received by its recipient without any monetary movement, for example, by the issuance of a demand note that is accepted as an absolute payment by the recipient. ...

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 3, 2020-0851991C6 F- Shares Donation to a tax exempt entity & dividend-- summary under Subsection 129(1.2) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(1.2) on an excepted gift of 10% of the shares of a CCPC to a public foundation and the shares’ redemption, s. 129(1.2) could deny the CCPC’s dividend refund In order to make a donation to a registered charity and public foundation (the "Donee"), a CCPC wholly-owned by Mr. ... Furthermore, the CRA took a similar approach in … 2016-0628181R3 by adding an opinion that any dividend … paid … on the shares of … the private corporation (Holdco) to the foundation (Foundation), which had previously acquired the shares as a result of the transfer of the shares by the testamentary spousal trust for the spouse of the deceased following the death of the spouse, would be considered not to be a taxable dividend, with the result that subsection 129(1. 2) would apply …. Whether the Purpose Test is satisfied is a question of fact that can only be resolved on the basis of the facts and circumstances …. ...

25 January 2018 External T.I. 2017-0709241E5- Subsections 125(3.2) & 125(5.1)-- summary under Subsection 125(5.1) Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(5.1) business limit is ground first based on taxable capital before it can be assigned Does the assignment of the business limit under s. 125(3.2) occur before or after the business limit reduction in s. 125(5.1)? After noting that under s. 125(5.1) “the business limit … is reduced on a straight-line basis if the total of the taxable capital of the CCPC (employed in Canada) and, if applicable, of [associated] corporations … exceeds $10 million … [so that] once the taxable capital … reaches $15 million its business limit would be zero,” CRA stated:. ...