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. … It is even more evident that all aspects of Dr. Axelrod’s reconstruction, in a patient’s mouth, of a significant portion of a tooth, using appropriate filling or restorative materials, were integral components of a composite supply. ...

. … If the corporate beneficiary is deemed under subsection 104(19) to have received the same dividend as the dividend received by the trust in the same taxation year as the dividend was, as a question of fact, received by the trust, then the legal fiction created by subsection 104(19) does not change the actual date that the dividend was received. ...

. – whereas here the taxpayers had substantiated the existence of an RCA by obtaining an actuarial report to support the amount of contributions necessary to provide them with a reasonable pension on retirement. ...

The Queen, 2022 TCC 68, rev'd 2024 FCA 42-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) circular use of capital dividends abused the purpose of the CDA Following preliminary transactions, on June 28, 2004, a Canadian holding company (“Micsau”) held all the shares, having a fair market value (“FMV”) and adjusted cost base (“ACB”) of $101.8M and $48.1M respectively, and a nominal paid-up capital (“PUC”), of a holding company (“3295940”), which held a minority shareholding (having an FMV of $88.5M and an ACB of $4M, reflecting the crystallization of the safe income on hand of such shares, and a nominal PUC) in another holding company (“Holdings” – which was majority-owned by an non-resident arm’s length investor), which carried on a Canadian generic-pharmaceuticals business. ...