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However, with respect to the preferred shares of Investco owed by the Estate, while those shares also appear to satisfy the votes and value test, they do not satisfy the ownership requirement set out in (b) [of “excluded amount”] …. ...

. … In the above situation, Jcorp is a corporation controlled by the J Trust and would for the purposes of section 55, therefore, be related to the J Trust pursuant to subparagraph 55(5)(e)(iii). ...

CCRA indicated that the question of whether the payment of the “deferred salary” was of income turned on whether it was “similar to one of the items that must be included in computing a taxpayer's income for the purposes of the … Act”. ...

However … article 72 of the Decree and the absence of an employment contract or subordination relationship seem to indicate that the relationship between the creditor and the debtor of the “deferred salary” does not constitute an employer-employee relationship. ...

A had been actively engaged on a regular, continuous and substantial basis for many years – but Mr. ...

., a group sickness or accident insurance plan (“GSAIP”), a private health services plan (“PHSP”), or a group term life insurance policy (“GTLIP”)) allows for the provision of benefit coverage to such individuals – although a GTLIP may only provide benefit coverage to current and former (including retired) employees. ...

CRA stated: [P]aragraph 94(2)(t) … applies to expunge the contribution after the time of the sale (i.e., from the time of the sale forward, the contribution is considered to have never occurred). ...

. … [F]or U.S. income tax purposes, the Canadian Branch profits of LLC3 are considered to be derived by the first entity in the corporate chain which is not treated as a fiscally transparent entity for U.S. income tax purposes. ...

(b) Here, in contrast, the fact that the trustee may make payments over the three years suggests that the trustee may have discretion and the payments may be voluntary – so that the payments to the charity over the three years may be eligible for the donation tax credit. ...

Reg. 204 imposes a requirement to file a T3 return where the trustee has control of, or receives, income, gains, or profits in the trustee’s fiduciary capacity – even if the Trust computes nil income. ...