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Kevin Wark, Michael O'Connor, "The Next Phase of Life Insurance Policyholder Taxation is Nigh", Canadian Tax Journal (2016) 64:4, 705 - 50-- summary under Paragraph 306(3)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 306- Subsection 306(3)- Paragraph 306(3)(b) Example of additional exempt test policy where >8% annual increase in death benefit (p. 720) Example 1 Assume that a life insurance policy is issued with $1 million of coverage. ... The second ETP has a death benefit of $30,831 ($1,114,639 − $1,083,808) and exempt-limit attributes based on the attained age at the time the additional ETP was created (the original issue age plus five years in this case) and an accumulating fund of zero. ...

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Clause 95(2)(a)(ii)(D) 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) Narrow scope of s. 93.1(4)(b)/same country residence requirement (pp. 20:75-76) [I]t appears that the only function of paragraph 93.1(4)(b) is to allow a determination of whether the inactive FA’s interest income—once deemed active by clause 95(2)(a)(ii)(D)—is included in the inactive FA’s exempt earnings or its taxable earnings. ... Clause (2)(d)(E) of the “exempt earnings” definition … applies to income that is recharacterized as active business income under clause 95(2)(a)(ii)(D). ...

Marquette, "Hybrid Sale of Shares and Assets of a Business", Canadian Tax Journal, (2014) 62:3, 857 – 79.-- summary under Subsection 191(4) Summary Under Tax Topics- Income Tax Act- Section 191- Subsection 191(4) CRA interpretation of specified amount (pp. 877-8) [I]n a hybrid transaction in in which a redemption of the shares will trigger a deemed dividend, a specific exemption in subsection 191(4) will treat the deemed dividend as an excluded dividend, to exempt the deemed dividend where the specified amount for which the shares are redeemed does not exceed the fair market value of the consideration for which they were issued. ...

The Queen – A Bridge Too FAAAR", International Tax Planning, Volume XIX, No. 1, 2013, p. 1284-- summary under Controlled foreign affiliate Summary Under Tax Topics- Income Tax Act- Section 17- Subsection 17(15)- Controlled foreign affiliate In the course of a submission that it was contrary to the scheme of the Act to apply s. 95(6)(b) to attack indirect loans to a non-resident parent, he stated: Purpose of CFA definition (p. 1290) Earlier changes to section 17 (introduced under the 1998 federal budget) also directly targeted the establishment of a Finco to make an "indirect loan" to a borrower Opco that was held by a non-resident ultimate parent corporation, but only where the borrower Opco was not a "controlled foreign Affiliate" under a special definition of that term that required Canadian control, though again not necessarily by the Finco owning taxpayer, and again subject to a transitional period. ...

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 Eligible Pension Income Summary Under Tax Topics- Income Tax Act- Section 60.03- Subsection 60.03(1)- Eligible Pension Income Overview (p. 488) …Spouses will now be able to split RCA distributions to the extent that the beneficiary of the income is at least 65 years of age and benefits received are in the form of a life annuity supplemental to an RPP. ...

– Limitations on Expenditures Pursuant to Sections 143.3 and 143.4", 2014 Conference Report, (Canadian Tax Foundation),14:1-36-- summary under Subsection 143.3(2) Summary Under Tax Topics- Income Tax Act- Section 143.3- Subsection 143.3(2) Denial of cost of property acquired with options (p. 14:7) [O]ne of the effects of section 143.3 is that the issuer will not have any cost for property it receives as consideration for granting an option to acquire an interest in the issuer. ...

– Limitations on Expenditures Pursuant to Sections 143.3 and 143.4", 2014 Conference Report, (Canadian Tax Foundation),14:1-36-- summary under Subsection 143.4(2) Summary Under Tax Topics- Income Tax Act- Section 143.4- Subsection 143.4(2) No grind if up-front payment (p. 19) Assume, for example that: Taxpayer A purchases capital property from Taxpayer B in exchange for $100, and Taxpayer A has a right to recover $20 from Taxpayer B in the event certain conditions are met and it is reasonable to conclude that that right will become exercisable. ...

John Lorito, Trevor O'Brien, "International Finance – Cash Pooling Arrangements", 2014 Conference Report, (Canadian Tax Foundation), 20:1-33-- summary under Subsection 15(2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2) Withholding based on net increase (p. 16) If the shareholder loan rules apply to loans made by a Canadian resident corporation to a non-resident, and there is a series of loans and repayments, the CRA has indicated that the withholding tax payable as a result of the deemed dividend shall be "based on the net increase of the loan during the taxation year of the lender" [fn 51: IT-119R4…]. ...

John Lorito, Trevor O'Brien, "International Finance – Cash Pooling Arrangements", 2014 Conference Report, (Canadian Tax Foundation), 20:1-33-- summary under Specified Right Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(5)- Specified Right Specified rights (defined as tantamount to ownership) rarely granted to creditors except re cash collateral (p. 9) [I]n simple terms, a specified right is the right of a person to treat the property as it if it was the person's own property including the right to encumber and sell the property and to use the proceeds in whatever manner the person chooses. ...

Xiao, "The 88(1)(d) Bump – An Update", 2013 Conference Report (Canadian Tax Foundation), pp.13:1-60-- summary under Paragraph 88(1)(c.9) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c.9) Options granted by virtue of employment not part of series (p. 13:29) [A] stock option granted to an employee by Bidco or Bidco's Canadian parent after closing to acquire shares would not be covered by new paragraph 88(l)(c.9) as such an option is not issued in consideration for the acquisition of options of Target. ...