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Content Provider which relates to the streaming of the digital content to Canco’s subscribers to the extent that the right in or to the use of the digital content is being used or reproduced in Canada” – except that: Canadian withholding tax can still apply, should the right in or to the use of the digital content be partly used or reproduced in Canada prior to being streamed to these foreign subscribers for viewing outside of Canada (but only to the extent of the payment that is related to the use or reproduction in Canada) or if it was being streamed in Canada. ...

Would this dividend be characterized as income that is derived directly or indirectly from a related business for s. 120.4 purposes – and would the answer change if the dividend was paid before 2018? ...

After noting that such policy did not apply to cash equivalent gifts and awards, such as where the employee receives reward points, which are accumulated and can be redeemed for a choice of goods, CRA stated that there could be “arguments that the points may not constitute a cash or cash equivalent award … since the points cannot be converted into cash and the number of goods that the employee can acquire, in exchange for the accumulated points, is very limited.” ...

. … [I]n 2002, the partner did not elect to add back income from that business pursuant to subsection 34.1(2). ...

. … Where an employee elects to receive the amount of the retiring allowance in instalments, it is our view that the instalments will be taxable in the year they are received. ...

“Where participating shares are exchanged for preferred shares having a FMV and a redemption value equal to the FMV of the participating shares, and because of the application of subsection 51(1) to the exchange, the ACB of the preferred shares is equal to the ACB of the exchanged participating shares, then the portion of the income earned on hand attributable to the participating shares immediately before the exchange is transferred to the preferred shares” – so that $8 million safe income of the Class A shares transferred to the 10,000 Class B shares. ...

. … [T]he CCRA considers overtime to be of an occasional nature if it is worked less than three (3) times per week. ...

(j) thereof): [A] transfer of property to a trust that is made for the sole purpose of securing the repayment of a debt or a loan within the meaning of paragraph (j) of the definition of "disposition" in subsection 248(1) nevertheless constitutes a disposition of property for the purposes of the Act, unless the transfer is also described in one of paragraphs (f), (g) or (k) of the definition of "disposition" …. ...

X – with the result that the Subject Shares would constitute ineligible property pursuant to s. 88(1)(c)(vi), since they would be acquired by a person (HoldcoB) who was a specified shareholder of Aco during the series and before the time at which HoldcoA last acquired control of Aco. ...

. … In our opinion, for the purposes of calculating the CEC of Amalco in Situations 1 and 2 described above, it should be considered that there is a continuation of the calculation of the CEC of Portfolioco and Subco in Amalco. ...