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" Ruling that the Dealer's Fee received by the Dealer either as a lump-sum payment or as periodic payments for facilitating the initial sale of the […] Shares to the Client, is consideration for an exempt supply of arranging for a financial service under paragraph (l) of the definition of financial service in subsection 123(1). However, if at any time after the initial sale, the Dealer "services" the Client's account in order to earn the Dealer's Fee, or if the fee is paid to a Dealer who did not facilitate the initial sale of the […] Shares, the supply of the services for which the Dealer's Fee is paid may be considered the provision of a taxable supply. ... [T]o "service" a Client's account includes, but is not limited to: regularly contacting the Client after the initial sale to review the status of the account and the appropriateness of the […] Shares held in the account in light of the Client's financial needs and investment objectives (e.g., holding the Client invested in those Shares, performing research and analysis); offer advice by recommending any appropriate change in the account; and provide assistance to the Client by answering any questions the Client may have regarding the […] Shares and on exercising any right or privilege connected to those Shares or to the account ...

2015 Ruling 2014-0527961R3- Deemed dividend under subsection 90(2)-- summary under Subsection 90(2) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(2) € and US$-denominated shares viewed as separate classes underline;">: €/US$ share structure. ... Given the current relative currency values, the paid in capital of the €€ shares on a per share basis is greater than the paid in capital of the US$ shares and, as a result, the €€ shares will be entitled on a per share basis to a larger proportion of the dividend. ...

After referencing the ss. 6(1) and 7 rules, CRA stated: Based on the facts, the Registration fees that the [Organization] collects from individuals who attend a particular […] conference are consideration for a supply of IPP in respect of which the Canadian rights can only be used in the province in which the […] conference takes place. ...

They each will own ½ of the common shares of the "Project General Partner" of New LP and subscribe for an equal number of LP units. ... See detailed summary under s. 122.1(1) – real estate investment trust. ...

2013 Ruling 2012-0443081R3- Distribution of pre-72 Capital Surplus on Hand-- summary under Personal-Use Property Summary Under Tax Topics- Income Tax Act- Section 54- Personal-Use Property Are non-interest bearing loans, for example to a non-resident corporation or to a non-resident child of a parent, "personal-use property" ("PUP") – so that for example they would not be "specified foreign property" in s. 233.3(1)? ... The Queen, 2011 TCC 47, and in finding that such debt generally would not be PUP, CRA stated: [T]o qualify as PUP under paragraph (a) the property must be owned and actually used primarily for the personal use or enjoyment of the taxpayer or a related person. … A debt would normally only qualify as PUP under paragraph (b), which requires the debt result from the disposition of a property which itself was PUP. ...

Preliminarily to this spin-off, an indirect Canadian subsidiary of Foreign Pubco (Canco – which is the distributing corporation) will transfer the Canadian business relating to Business B as well as related foreign subsidiaries held directly (Forsub) or through a partnership (Forlp) and a partner thereof (Canco Sub 4) to the transferee corporation (TCo – a ULC). ... TCo (which will be directly held by Newco 3 and through transactions which are heavily redacted – see perhaps para. 122) will be indirectly transferred to Foreign Pubco, whereas Canco will become an indirect subsidiary of Foreign Spinco. ...