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20 June 2023 STEP Roundtable Q. 3, 2023-0968091C6- Trust Reporting – Definition of Money and Treatment of Dividend Receivable-- summary under Subparagraph 150(1.2)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.2)- Paragraph 150(1.2)(b)- Subparagraph 150(1.2)(b)(i) gold or silver bar or coin would not qualify as “money”/ dividend receivable not included in “shares” Pursuant to s. 150(1.2)(b), the exception from trust reporting requirements under s. 150(1.1)- that may be available to individuals with no Part I tax payable or relevant dispositions- can apply to a trust for a particular tax year where the trust holds assets restricted to listed types of property including “money,” with an FMV not exceeding $50,000 throughout the year. ...

17 January 2025 Internal T.I. 2024-1029791I7 F- SSUC- Rémunération de la haute direction / CEWS--- summary under Executive Remuneration Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Executive Remuneration no adjustments are made to an eligible entity's Statement of Executive Compensation for NEOs filed pursuant to NI 51-102 for CEWS repayment purposes The Directorate found that the “executive remuneration” (as defined in para. ...

17 January 2025 Internal T.I. 2024-1029791I7 F- SSUC- Rémunération de la haute direction / CEWS--- summary under Subsection 125.7(14) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(14) repayment based on NI 51-102 statements, without adjustments Ss. 125.7(14) and (14.1) could require exchange-listed eligible entities to repay all or part of the CEWS they had received based inter alia on the excess of their executive remuneration over the 2019 base level. ...

& Section 116116(5)-- summary under Subsection 116(5) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(5) no acquisition of property by the obligor corporation when its debt repaid or employee stock option exercised S.49(3) did not apply to deem the exercise of employee stock options held by a non-resident former employee to not be a disposition of the options, given that s. 49(3) applied only to capital property, whereas employee stock options are governed by s. 7. ...

18 March 2003 External T.I. 2003-0002915 F- Subsections 40(3.3) & 40(3.4)-- summary under Subsection 40(3.4) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.4) taxpayer can designate order of disposition On December 16, 2002, Holdco sold 200 of its 1,000 common shares of a public corporation to an unaffiliated person $1,500, realizing a capital loss of $500, and less than 10 days after December 16, 2002, Holdco acquired 200 new common shares of the public corporation at a cost of $1,500. ...

2012 Ruling 2010-0355941R3- reverse subsidiary merger- 87(1) & 87(11)-- summary under Subsection 87(11) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(11) survivor style amalgamation on Code reverse triangular merger Under a BC plan of arrangement, a BC corporation ("SubcoTarget") is merged with its wholly-owned BC subsidiary ("Target") to form "Amalco" with the same effect as if they had amalgamated under section 269 of the Business Corporations Act (BC), except that the legal existence of Target does not cease and it survives the merger, Subco ceases to exist and the property of Subco (other than its shares of Target, which are cancelled) become the property of Target. ...

2012 Ruling 2010-0355941R3- reverse subsidiary merger- 87(1) & 87(11)-- summary under Subsection 87(1) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(1) reverse triangular "E" merger- survivor style amalgamation Under a BC plan of arrangement, a BC corporation ("SubcoTarget") is merged with its wholly-owned BC subsidiary ("Target") to form "Amalco" with the same effect as if they had amalgamated under section 269 of the Business Corporations Act (BC), except that the legal existence of Target does not cease and it survives the merger, Subco ceases to exist and the property of Subco (other than its shares of Target, which are cancelled) become the property of Target. ...

2011 Ruling 2011-0416891R3- Fees for Digital Content & Management Services-- summary under Paragraph 212(4)(a) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(4)- Paragraph 212(4)(a) management of on-line store A US LLC ("Corporation C"), whose sole member was a US corporation qualifying for benefits under the Canada-US Convention, ran a platform for the provision of "Digital Content" (movies, television shows, music videos, documentaries and similar audio-visual content) which it (and affiliated corporations) were permitted to distribute under content licence agreements with the third-party holders of the copyright. ...

2011 Ruling 2011-0416891R3- Fees for Digital Content & Management Services-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 A US LLC ("Corporation C"), whose sole member was a US corporation qualifying for benefits under the Canada-US Convention, ran a platform for the provision of "Digital Content" (movies, television shows, music videos, documentaries and similar audio-visual content) which it (and affiliated corporations) were permitted to distribute under content licence agreements with the third-party holders of the copyright. ...

28 November 2010 CTF Roundtable, 2013-0487431C6- Value of Vote-Only Shares – 2010 CTF Conference-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares premium for voting rights The questioner referenced the CRA statement at the 2009 British Columbia Tax Conference that, in the context of an estate freeze of a Canadian-controlled private corporation, where the freezor, as part of the estate freeze, keeps controlling non-participating preference shares in order to protect his economic interest in the corporation, CRA generally accepts that no premium should be attributed to such shares in determining their fair market value under s. 70(5), and asked whether this position also applies for the purposes of s. 104(4)(a), e.g., re the deemed disposition arising on the death of the spouse who is the beneficiary of a spousal trust. ...