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The loss business was broadly identified as marine construction, rather than being limited to marine construction in a specific location, based upon evidence that marine construction businesses typically operate in various areas throughout the country; [fn: 50: Canadian Dredge & Dock Co. v. ... The loss business was found to be selling clothes, whether those clothes were sold to individuals or to retail and wholesale merchants, and whether they were ladies' clothing or men's and boy's clothing; [fn 53: Martin & Co. ...

[fn 31: … 1995 OECD guidelines, at paragraph 5.28 (emphasis added). … the need for the documents should be balanced by the costs and administrative burdens, particularly where this process suggests the creation of documents that would not otherwise be prepared or referred to in the absence of tax considerations. ... What is reasonable is based on what a reasonable business person in the taxpayer's circumstances would do, having regard to the complexity and importance of the transfer pricing issues that arise in the taxpayer's case. … [R]egardless, we have seen the CRA assert penalties in circumstances where it ought to be uncontroversial that reasonable efforts were made. ...

Jenny Yu, "Departure Tax for Small Trusts", Canadian Tax Focus, Vol. 7, No. 1, February 2017, p. 8-- summary under Subsection 220(4.51) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(4.51) No relief from security requirement for small trusts/emigration under s. 94(5) (p. 8) When an individual ceases to be a resident of Canada and has a deemed disposition of certain property…[s]ecurity is automatically considered to be posted for essentially the first $16,500 ($50,000 × 33%) of federal tax (subsection 220(4.51)). However, as the CRA has confirmed (2015-0608051E5 …), this deemed-security rule does not apply to trusts that cease to have a Canadian residence and have a corresponding departure tax.... ...

(c)(iv) does not expressly address when eligible group entity status is tested, and refers to “an eligible group entity in respect of the taxpayer for the taxation year ” even though the eligible group entity definition provides a point-in-time test – perhaps an interest payment made by an entity is relevant under s. ...

Examples … are IFR [and] foreign income covered by tax credits claimed under subsection 126(1) and (2) …. ...

The notion that one can do so is closely related to the 18 th-century (and later Marxist) labour theory of value – an intuitive notion that has since been thoroughly debunked in the economic literature. ... Certain "Secondary income" – derived from income previously subject to attribution – will be subject to TOSI. ...

. … Generally, paragraph 104(4)(a.3) triggers a deemed disposition of the property held by a personal trust if a taxpayer transfers property to the trust and it is reasonable to conclude that the property was transferred in anticipation that the taxpayer would subsequently cease to reside in Canada, and then the taxpayer did subsequently cease to reside in Canada. ... [Footnote 78- $100 "designated income" less "40% part X1I.2 tax = $60 after-tax proceeds available to distribute less 25% (or 15%) = $45 or ($51) after tax proceeds.] ...

Under the first alternative, the deemed amount of income received by the person whose status as a majority interest beneficiary is at issue and each other affiliated person is $300 ($100 × 3). Under the second alternative, the deemed amount of income received by the person whose status as a majority-interest beneficiary is at issue and each other affiliated person is collectively $100. … The former approach is supported by the reference in subparagraph 251.1(4)(d)(i) to the amount of income or capital of the trust that “a” person may receive as “a” beneficiary and does not refer to the amount of income or capital that “a person and all persons with whom the person is affiliated” may receive as beneficiaries. This approach is also consistent with the stated purpose of subparagraph 251.1(4)(d)(i) …. ...

[A]ssume that Opco is a wholly owned subsidiary of Holdco, which owns 100 common shares of Opco worth $ 1 million (with nil ACB and PUC). ... Appropriateness of preliminary transactions to stream ACB to non-redeemed shares (pp. 6:32-33) [I]t appears [having cited 2015-0610681C6] that the CRA would challenge a preliminary transaction segregating pre-existing ACB from shares to be subsequently redeemed …. [S]uppose that Holdco had pre-existing ACB of $100,000 and undertook a preliminary share-for-share exchange … under subsection 85(1). ...

Deletion of "required to be" from s. 92(1)(a) (pp. 4-5) [T}he wording in respect of the ACB addition mandated by paragraph 92(l)(a) was amended from "any amount required to be included... by reason of subsection 91(1) … in computing the taxpayer's income" to "any amount included … under subsection 91(1)... in computing the taxpayer's income. ...