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X of the preferred shares would be attributable to the capital gains deduction – so that there would be a deemed dividend of $500,000 paid by Cco to Mr. ...

X, CRA indicated that Amalco shares that were substituted for his Holdco common shares had not been held by anyone other than him, and that, prior to being replaced by Holdco shares, the original Opco share had not been owned by anyone other than him – and in this regard, stated that s. “110.6(1)(e) can apply respecting multiple substitutions.” ...

(a)(ii) of that definition, that “ prima facie, the mere fact of M-1 and C-1 acting as directors of Investco would not be sufficient in itself to consider that they were actively involved, on a regular basis, in the activities of Investco's business,” but that the “ownership test” in s. ...

On 20 June 2013 FA2 made the $1,500 "FA2 Loan" to Canco for 10 years – but FA2 was wound-up into FA1 on 20 February 2014. ...

. … With a dividend in the order of magnitude of $35,000…we could conclude that the reduction is significant or the increase in cost is significant. ...