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7 January 2003 External T.I. 2002-0133675- Cash Call Provisions & Contingent Rts-- summary under Paragraph 251(5)(b) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b) Ss.251(5)(b) and 256(1.4) applied to a shareholders agreement that provided that where one of the shareholders failed to advance money to the company following an operating fund deficiency, the other shareholders could choose to advance the funds which the defaulting shareholder had failed to advance, in which event the defaulting shareholder would have its equity diluted. ...

8 November 1999 External T.I. 9914135- INTEREST & PENALTY RE MICHIGAN SBT-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose Penalties in respect of the Michigan single business tax do not meet all the conditions specified in IT-104R2, para. 3 and therefore, unless the facts show otherwise, are not deductible. ...

23 March 2021 TEI Roundtable, 2021-0879631C6- CERS- Net Leases, Qualifying Revenue & Deadlines-- summary under Subsection 125.7(2.1) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(2.1) table of filing deadlines What are the deadlines to file an application for the CEWS and the CERS? ...

1 March 2001 External T.I. 2000-0050275 F- Remboursement de prime / enfant infirme-- summary under Subsection 146(8.1) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(8.1) overview or rules for transfer of taxpayer’s RRSP on death to financially dependent child Regarding whether the taxpayer’s RRSP could be transferred upon death to the taxpayer’s daughter free of tax, CCRA discussed the rules under ss. 146(8.9) and (8.1) for the transfer to a financially dependent child. ...

1 February 2001 External T.I. 2000-0041535 F- Actionnaire rattaché / droit de 1er refus-- summary under Paragraph 4901(2.2)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 4901- Subsection 4901(2.2)- Paragraph 4901(2.2)(b) comments in IT-419R, para. 13 re shotgun clauses etc. are applicable to Reg. 4901(2.2)(b) CCRA confirmed that the comments in IT-419R, para. 13, regarding the scope of the contingent right to acquire shares also applied to the interpretation of Reg. 4901(2.2)(b). ...

2006 Ruling 2005-0151001R3- Prescribed Shares / plan of arrangement-- summary under Subsection 6204(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 6204- Subsection 6204(3) where pursuant to an arrangement agreement that is implemented under a plan of arrangement, employee stock options previously granted by the "Target" are transferred by the employees to Target in exchange for cash amounts equal to their in-the-money value before the acquisition pursuant to the agreement and plan by the purchaser of 100% of the shares of Target for cash consideration, such purchaser will not be a "specified person" at the time the options are so transferred. ...

16 November 2011 External T.I. 2011-0419191E5- Foreign Intermediaries & Canadian Owners-- summary under Subsection 215(6) Summary Under Tax Topics- Income Tax Act- Section 215- Subsection 215(6) breach of undertaking Where a foreign financial intermediary ("FFI") has represented to a Canadian financial institution ("CFI") that the beneficial owners of securities in a subaccount are eligible for a 0% rate of withholding based on Treaty exemptions and CFI later learns that there are Canadian beneficial owners in those accounts, CFI should withhold at a 25% rate as FFI has breached its undertaking to provide a replacement certificate which is accurate. ...

21 May 2009 IFA Roundtable Q. 1, 2009-0321451C6- Meaning of beneficial owner in Article 10, 11 & 12-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 In the Prévost Car case, "the Court implied that where an intermediary acts as a mere conduit or funnel in respect of an item of income, the intermediary would not have sufficient economic entitlement to the income to be considered the 'beneficial owner'. ...

21 May 2009 IFA Roundtable Q. 1, 2009-0321451C6- Meaning of beneficial owner in Article 10, 11 & 12-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 In the Prévost Car case, "the Court implied that where an intermediary acts as a mere conduit or funnel in respect of an item of income, the intermediary would not have sufficient economic entitlement to the income to be considered the 'beneficial owner'. ...

2006 Ruling 2004-0106101R3- Class of German Arrangement & Treaty Benefits-- summary under Subsection 104(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(1) German real estate investment fund treated as trust Ruling that an open-end real estate fund established under the Investment Companies Act (Germany) (and to be continued under the Investment Act (Germany)) would be treated as an inter vivos trust that was not a personal trust for purposes of the Act in respect of its proposed investments in a Canadian partnership. ...