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To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayers or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; (iii) under objection by the taxpayers or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired. ...

.), c.1, as amended (the "Act"); (b) "ACB" means "adjusted cost base" as that expression is defined in section 54 and subsection 248(1); (c) "arm's length" has the meaning assigned by subsection 251(1); (d) "BCA" means the Business Corporations Act XXXXXXXXXX as amended; (e) "capital property" has the meaning assigned by section 54; (f) "cost amount" has the meaning assigned by subsection 248(1); (g) "disposition " has the meaning assigned by section 54; (h) "financial institution" has the meaning assigned by subsection 142.2(1) (i) "ineligible property" has the meaning assigned by paragraph 88(1)(c); (j) "investment dealer" has the meaning assigned by subsection 142.2(1); (k) "mark-to-market property" has the meaning assigned by subsection 142.2(1); (l) "PUC" means paid-up capital as that expression is defined in subsection 89(1); (m) "registered securities dealer" has the meaning assigned by subsection 248(1); (n) "proceeds of disposition" has the meaning assigned by section 54; (o) "public corporation" has the meaning assigned by subsection 89(1); (p) "related persons" has the meaning assigned by subsection 251(2); (q) "safe income on hand" in respect of particular shares of a corporation at a particular time refers to the income earned or realized, within the meaning of paragraphs 55(5)(b) or (c), by any corporation after 1971 and before the safe-income determination time to the extent that it is on hand and can reasonably be considered to contribute to the capital gain that would be realized on a disposition at fair market value of the particular share of the corporation; (r) "safe income determination time" has the meaning assigned by subsection 55(1); (s) "stated capital" has the meaning assigned by XXXXXXXXXX of the BCA; (t) "subsidiary wholly-owned corporation" has the meaning assigned by subsection 248(1); and (u) "taxable Canadian corporation" has the meaning assigned by subsection 89(1). ...

(iii) OPCO devra payer à PUBLICO des redevances annuelles correspondant au plus élevé de: (a) XXXXXXXXXX $ et (b) coût de maintien des marques de commerce plus XXXXXXXXXX%. ...

Reasons: (1) Ruling granted previously in similar circumstances- transaction not to confer benefit – in particular, transaction at less than FMV permitted tax deferred transaction with restriction of ACB of the foreign affiliate shares to amount of the transfer. (2) The transactions are not a misuse or abuse of the Act or its provisions. (3) The “one of the main purposes” condition has not been met. ...

2020 Ruling 2020-0860231R3- Post-mortem planning Unedited CRA Tags 84(2), 84.1, 88(1), 245(2) * Principal Issues: Post-mortem pipeline and bump transaction ruling Position: Favourable rulings issued. ...

As such, F’s deemed proceeds of disposition were $XXXXXXXXXX, pursuant to subparagraph 70(6)(b)(ii), resulting in $ XXXXXXXXXX capital gain for F’s XXXXXXXXXX taxation year. ...

Effect of Paragraph 1(2)(c) of EIA for Income Tax Purposes Paragraph 1(2)(c) of the EIA provides as follows: (2) For the purposes of this Act [...] ...

(page 15 of Text, Commentary and Cases on Trusts (fourth edition) by Oosterhoff & Gillese (student edition)) ii) The three certainties To create a trust, there must be certainty of intention to create the trust, the subject matter must be described with such certainty that it is ascertained or capable of ascertainment, and those who are to benefit from the trust- that is, the objects or beneficiaries- must also be described in terms clear enough that the trust obligation can be performed properly. ...

As a result of the redemption by TransfereeCo of its TransfereeCo Preferred Shares as described in paragraph 14 above and the consequential purchase for cancellation of the Class XXXXXXXXXX common share of XXXXXXXXXX as described in paragraph 15 above: (a) By virtue of paragraphs 84(3)(a) and 84(3)(b) of the Act: ••• TransfereeCo will be deemed to have paid, and XXXXXXXXXX will be deemed to have received, a taxable dividend equal to the amount by which the amount paid in respect of the redemption of the TransfereeCo Preferred Shares exceeds the PUC thereof; and (ii) XXXXXXXXXX will be deemed to have paid, and TransfereeCo will be deemed to have received, a taxable dividend equal to the amount by which the amount paid in respect of the purchase for cancellation of the common share of XXXXXXXXXX exceeds the PUC thereof; (b) Provided that neither of XXXXXXXXXX nor TransfereeCo is entitled to a dividend refund in respect of its taxation year in which it is deemed to pay the dividend referred to in (a)(i) or (ii) herein, neither of XXXXXXXXXX nor TransfereeCo will be subject to Part IV tax under subsection 186(1) of the Act in respect of such dividend; and (c) The taxable dividends deemed to have been received by XXXXXXXXXX and TransfereeCo as a result of the redemption and purchase for cancellation referred to in paragraph (a) herein will be deductible by each of them in computing its respective taxable income pursuant to subsection 112(1) of the Act. ...

7 February 1991 Income Tax Severed Letter- Review of the General Anti-avoidance Rule Course Material- Lesson #3 Unedited CRA Tags 245(2) Subject: Review of The General Anti-Avoidance Rule Course Material- Lesson # 3 We have now had a chance to complete a technical review of the course material titled “The General Anti-Avoidance Rule”. ...