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Summary of 10 August 2021 Short Form Base Shelf Prospectus of Sprott Physical Uranium Trust under Commodity Funds – Metals Funds. ...

CRA ruled that the pref redemption would not reduce the safe income on hand attributable to the common shares – noting in its summary that this was because there was no inherent gain on such pref. ...

On a subsequent third-party sale by the trust of those shares, the QSBC definition requires that the shares have been owned by the trust, or a person related to the trust, for the prior 24-month period – and in this regard, s. 110.6(14)(c)(ii) provides that where a person who sold shares to a trust was related to all the beneficiaries, that person and the trust are deemed to have been related for the above purpose. ...

CRA stated: If the facts and circumstances of a specific case demonstrate that the financial dependence of one party on another is such that it is possible for the CRA to conclude that a transaction or series of transactions was entered into between persons not dealing with each other at arm's length under any of the criteria listed in … S1-F5-C1, [para. 1.38, respecting a common mind directing the bargaining, acting in concert or de facto control], then such dependence may be sufficient to conclude that the parties are not dealing at arm's length. ...

IV tax under s. 186(1)(b) in the hands of Holdco – so that the exclusion in the preamble to s. 55(2) applies to the extent that such Pt. ...

Summary of 2021 APFF Financial Strategies and Instruments Roundtable, Q.3 under s. 54 – superficial loss. ...

Summary of Tu Vu, “Application of Disproportionate UFT Election,” Canadian Tax Focus, Vol. 11, No. 4, November 2021, p. 15 under Reg. 5907(1)- underlying foreign tax applicable – para. ...

Summary of APFF Financial Strategies and Instruments Roundtable, Q.9 under s. 204.2(1.2)- undeducted RRSP premiums – J. ...

In particular having regard to the CRA view that “to be a right or thing [under s. 70(2)] … the individual would have to be legally entitled to receive the amount at the time of the individual’s death (the right would have to exist)” CRA considered that even though an individual annuitant who died part way through the year was allocated the income that had been earned in the year up to the time of death on the T3 slip received by his executors, he had no legal entitlement to the allocated amounts. ...

(e) of the specified shareholder definition to wholly-own Holdco, so that each child also would be a specified shareholder, under that definition, of the related corporation (Subco) – thus the test in s. 74.4(2)(a) also would be satisfied. ...