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“Specified Event” means the occurrence of: (i) a significant health event or other emergency that … creates an unexpected change in financial circumstances and/or financial need, (ii) a material deterioration in the Canadian economy, (iii) a material change in personal income tax rates …, or (iv) any other event that could not have reasonably been foreseen by the Participant and creates an immediate need by the Participant for the use of funds held by the Trustee under the terms of the New RCA Trust. Employerco will cause the Existing RCA Trustee to transfer a lump sum (equalling ½ of the actuarial equivalent value of the benefits accrued to the date of settlement) directly from the Existing Supplemental Plan to the custodian of the New Supplemental Plan, and apply for a corresponding amount of refundable tax to be now held by CRA for the account of the New rather than Existing RCA Trust. ...

The Direct Subtrusts will simultaneously transfer their assets to Trust A (newly formed by Taxpayer, which holds one unit) for no consideration other than the assumption of their liabilities, so that they cease to exist; and Trust A will not file the election in s. 248(1) – disposition, (f)(v) with a view to that disposition exclusion applying. ... Trust A will transfer all of its property to REIT #2 for no consideration other than the assumption of secured debts (with any unsecured debts being paid off by Trust A) – so that Trust A will cease to exist. REIT #2 will file the election in s. 248(1) – disposition, (f)(v) for s. 107.4(3) to apply instead and Trust A will not file the election in s. 107.4(3)(a)(i) to have the transfer occur otherwise than at cost amount. ...

In finding that the supplies of T-shirts by the charity to the donors were not exempt, with HST or GST applying on the consideration of $X for each supply of a T-shirt, CRA stated: excluded from exemption under paragraph 3(a) of Part V.1 of Schedule V is a supply by way of sale of any personal property or service made by a charity in the course of a fund-raising activity where: • the charity makes supplies of such property or services in the course of that activity on a regular or continuous basis throughout the year (any period of twelve consecutive months) or a significant portion (30% or more) of the year; or • the agreement for the supply entitles the recipient to receive from the charity property or services on a regular or continuous basis throughout the year or a significant portion of the year.....as XXXXX supplied the t-shirts to contributors on a weekly basis from XXXXX to early XXXXX, it sold the t-shirts on a regular and continuous basis throughout a significant portion of the year. ...

In order to get rid of a subtrust which now is an asset of REIT #1 (and which was the result of an earlier s. 248(1) – disposition, (f) consolidation of four predecessor subtrusts into one), there will be s. 107.4 transfers of all its assets to a new subtrust ("REIT #2"), followed by a distribution of its units by REIT #1 to the REIT #1 unitholders. ... See detailed summary under s. 132.2 – qualifying exchange. ...

2013 Ruling 2013-0488351R3- Conversion of a MFC to a MFT-- summary under Subsection 107.4(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107.4- Subsection 107.4(1) conversion of MFC to MFT and subtrust elimination The same (mutual fund corporation) taxpayer as for 2013 Ruling 2011-0395091R3 (immediately below) obtained essentially the same rulings for transactions which now reflected its acquisition of "Target" trust before the implementation of the merger of the taxpayer under s. 132.2 into REIT #1 (the internally-created replacement mutual fund trust) and the elimination of various subtrusts using s. 107.4 (or s. 248(1) – non-disposition) transfers and the s. 132.2 merger rules. ... See summary under s. 132.2 – qualifying exchange. ...

This was to be accomplished by ACo transferring its FA1 shares on a s. 85.1(3) rollover basis to a newly-formed non-resident subsidiary (New FA), with New FA then transferring its FA1 shares to BCo for a note – which then was to be repaid in cash out of share subscription proceeds from ACo, and with FA1 then distributing such cash to ACo (with a Reg. 5901(2)(b) designation being made). ... In order to satisfy a CRA requirement that the cost to BCo of the FA1 shares (which were excluded property) be limited to the sum of their relevant cost base and the net surplus (being exempt surplus) of FA1 – rather than being stepped up to their higher fair market value, the note equalled such sum. ...

[F]or each class of identical securities held by a Participating … Public Fund, [it] will transfer the Transfer Percentage of such securities to its corresponding New Fund. If and as necessary, each such Participating … Public Fund may take advantage of the provisions of subsection 107.4(2.1) of the Act to avoid the need to transfer a fractional share to its corresponding New Fund. ...

Ruling: The negative repo spread … will not be considered to be interest or an amount paid or credited as, on account or in lieu of, or in satisfaction of interest for the purposes of paragraph 212(1)(b) …. ...

Proposed transactions The shareholders of Opco will transfer their shares on a s. 85(1) rollover basis to a newly-incorporated corporation (Holdco – which had no shares issued on its incorporation by Messrs. ... Additional information The estate planning transactions … will not be carried out with a view to completing the series of transactions that includes the Proposed Transactions and would be completed notwithstanding the implementation of the Proposed Transactions, and vice versa. ... Other comments CRA has not reviewed the allocation of safe income between Opco and Realtyco but is "generally of the view that Safe Income should be allocated in a manner consistent with documents 2020-0861031C6 and 2021-0889611E5 ". ...

Rulings: Each Investor's interest in the Foreign Partnership will be taxable Canadian property Such interest will be treaty-protected property for Investors resident in Foreign Countries 1 through 4 provided stipulated conditions relevant to the applicable Treaty are satisfied, as follows: Treaty 1- the only properties of the Foreign Partnership are the shares of Foreign Parent, the Foreign Parent Loans and the Foreign Subsidiary Loans Treaty 2 – the Investor does not have a controlling interest, (a controlling interest being where the Investor and persons related to the Investor have an interest of 50% or more), in the Foreign Partnership Treaty 3 – no additional conditions Treaty 4- the Investor and any persons related to or connected with the Investor are entitled to an interest of less than 10% of the income and capital of the Foreign Partnership immediately before the Disposition Time Treaty 5- not treaty-protected property ...