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. … As property is distributed to FA1 and FA2 on the dissolution on a rollover basis under the tax law of Country X, there would be no "earnings" created as a result of the wind-up of FA1 and FA2. ...

" … [N]o amount was expended by the taxpayer for advertising. Thus,,, the taxpayer is not entitled to an amount allocated in computing its income. ...

Logging …. We are not currently disposed to take a position respecting such a hypothetical scenario, but would be prepared to consider this question in the context of an advance ruling request. ...

9 October 2015 APFF Roundtable Q. 1, 2015-0595751C6 F- Deductibility of financing fees and 20(1)(e)(v)-- summary under Paragraph 20(1)(e) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e) discharge of a debt through its assumption or cash proceeds from sub transferee denies a s. 20(1)(e)(v) deduction The exclusion in s. 20(1)(v)(v) for settlement occurring "as part of a series of borrowings or other transactions and repayments" applies where (i) the debt of the taxpayer is settled by the taxpayer transferring assets to a subsidiary in consideration inter alia for an assumption of the debt (with the taxpayer being released) – or (ii) where the debt is not assumed on the asset transfer and the taxpayer instead uses cash consideration received from the subsidiary (funded out of a borrowing by it) to discharge the debt. ...

. … [I]n situations where the Prescribed Rate is not representative of the normal yield rate, the Prescribed Rate will not be the rate which is used in calculating the value of the benefit to the shareholder. ...

. … Accordingly, the de-registration of an individual’s TFSA would cause a permanent loss of TFSA savings room for the individual. ...

9 October 2015 APFF Roundtable Q. 25, 2015-0598321C6 F- Omission of deducting a dividend under 112(1)-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) IC 75-7R3 still applies to requests for refunds for errors made in already-filed returns In response to the specific example of a corporation which discovered that it had failed to claim the intercorporate dividend deduction in a return for which the 90-day objection period has expired, CRA noted that it still stands by IC 75-7R3, dated July 9, 1984, respecting the circumstances in which it will make a reassessment for a reduction in tax payable – so that such an adjustment would be available provided that the normal reassessment period does not expire without the giving of a waiver. ...

. … In the case where the expense is paid or payable only after the period specified in subparagraph 42(1)(b)(i), subparagraph (ii) deems the expense to be a capital loss of the vendor from the disposition of a property. ...

., it was in respect of a “restrictive covenant”) – or, failing that, it would be included in the taxpayer’s income as an inducement under s. 12(1)(x). ...

. … [O]nce the CRA advises the taxpayer that it accepts the voluntary disclosure and that it will revise the income or the tax payable of the latter under the VDP, we generally will allow the deduction, under paragraph 60(o), for professional fees incurred from that time onwards by the taxpayer in advancing its claims respecting the revision. ...