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Conversely, if it was determined that the corporation did not carry on a business, the excluded share exception would not apply – but s. ...

If a Treaty has no time-limits itself, then the usual domestic limits apply, for example, under s. 152 – again, subject to any changes provided in Bill C-20, that extend those delays for periods up to six months, but no later than December 31, 2020. ...

15 September 2020 IFA Roundtable Q. 5, 2020-0853401C6- IFA 2020 Q5: TPM-17 and COVID-19-- summary under Paragraph 247(2)(a) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2)- Paragraph 247(2)(a) Canadian governmental COVID assistance likely will not reduce cost under cost-plus transfer-pricing methods TPM-17 provides that the cost base should not be reduced by government assistance unless there is reliable evidence that arm’s length parties would have done so – so that it generally is presumed that the Canadian taxpayer will keep the assistance. ...

CRA stated that it was “not prepared to take an administrative position to consider that subsection 247(7) would apply in respect of the loan between the FA and LP ….” ...

Therefore, the 87(1)(a) condition would be met – all property of the predecessor corporation becomes property of the new corporation by virtue of the amalgamation. ...

3 November 2021 CTF Roundtable Q. 14, 2021-0911951C6- Failure to properly file a T1135-- summary under Foreign Affiliate Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Foreign Affiliate s. 95(1) FA definition is broader than under s. 233.4 The T1135 form and related disclosure stated that specified foreign property “does not include … a share of the capital stock or indebtedness of a foreign affiliate,” without disclosing that the definition “foreign affiliate” for these purposes is narrower than the definition in s. 95(1). ...

However, planning contemplating the payment of an unreasonable amount of salary, particularly in circumstances similar to those described in [this] scenario … could be considered abusive,... ...

. … If the purpose of such a transaction were to avoid CCPC status in order to defeat the purpose and intent of various anti-avoidance rules applicable to investment income, including section 123.3 and subsection 123.4(2), the CRA would consider, depending on the circumstances, application of the GAAR under subsection 245(2). ...

. … In the situation where A Inc. would not be a partner of AB immediately before the time at which AB would cease to exist, we are of the view that subsection 98(5) could not apply. ...

7 October 2021 APFF Financial Strategies and Instruments Roundtable Q. 7, 2021-0899681C6 F- Stock option, Short sale and Identical property-- summary under Subsection 7(1.31) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1.31) s. 7(1.31) applies to sale of shares acquired on exercise to cover short, but not to the sale of the shorted shares An employee, who engages in a short sale transaction to finance the exercise of stock options on the shares of the individual’s employer, short sells identical shares borrowed from a third-party lender and uses the short sale proceeds to inter alia fund the option exercise – and then uses the shares acquired on exercise to cover the short position. ...