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31 August 2005 Internal T.I. 2005-0134831I7 F- Capital Gains Exemption Strip-- summary under Subsection 40(3.6) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.6) individuals holding high-ACB/low-PUC prefs and low ACB/PUC common shares preserved that ACB under s. 40(3.6)(b) for surplus-stripping purposes on their prefs’ redemption S. 84.1 did not apply to individuals transferring preferred shares – whose ACB previously had been stepped up by them under s. 110.6(2.1)- to common shares under s. 40(3.6)(b) (upon the redemption of those preferred shares in their hands), with those common shares then exchanged by them for inter alia high-PUC preferred shares of new Holdcos, which were then redeemed in their hands for cash. ...

6 October 2005 External T.I. 2005-0146061E5 F- Coop de travailleurs actionnaire- montants versés-- summary under Subsection 136(2) Summary Under Tax Topics- Income Tax Act- Section 136- Subsection 136(2) workers shareholder cooperative qualified Regarding the qualification of a workers shareholder cooperative, CRA stated: As stated in F9902745 … a workers cooperative provides services to its members where it employs its members directly or indirectly. ...

Furthermore … the Plan would be intended to provide benefits to the employee upon retirement and would not be primarily intended to fund a leave of absence from the employee’s employment, thereby contravening the requirements of [Reg.] 6801(a)(i) of the Regulations. ...

In this case, the taxpayer "acquired" the … operating agreements for such a cost. ...

27 January 2006 External T.I. 2005-0164611E5 F- Société immobilière de pension- sens de location-- summary under Clause 149(1)(o.2)(ii)(A) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(ii)- Clause 149(1)(o.2)(ii)(A) providing meals, medical services and housekeeping in a seniors apartment would put the corp. offside Regarding whether a pension fund real estate corporation that owns (in joint tenancy with a taxable corporation) a building that includes apartments rented to independent seniors can be considered to have limited its activities to the leasing or managing of capital property that is real property for the purposes of clause 149(1)(o.2)(ii)(A) if it provides meals, medical services and housekeeping that are billed separately, CRA stated: [T]he services provided by the Corporation … do not constitute leasing or managing capital property for the purposes of clause 149(1)(o.2)(ii)(A). ...

For example … the corporation's income from the trust would not be included in the computation of its total investment income if that income was incidental to an active business carried on by it. ...

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21 November 2017 CTF Roundtable Q. 10, 2017-0724291C6- Tax Shelters-- summary under Subsection 96(2.2) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(2.2) no rulings on at risk rules’ application to tax shelter LPs In indicating that it “will generally not issue an advance income tax ruling … with respect to a limited partnership financing arrangement involving the application of the at-risk rules in the context of a tax shelter, as defined in subsection 237.1(1),” CRA stated: Although the CRA does not verify the representations of fact at the time of the Ruling, they should be capable of verification at that time. ...

. … If the name does not match after several attempts then the authorization will be denied and they will be presented with a message for the owner to contact the CRA. ...

Pubco) received the repayment of a loan that it had made to a non-resident affiliated corporation (Forco2, which was not a foreign affiliate of Canco3), and used the repayment proceeds to purchase note receivables from group companies within the Forco2 silo and also to pay a dividend to Canco3 – which then lent some of this money “back” to Forco2 and also repaid loans owing to Canadian affiliates held in a separate silo from the Canco3 or Forco 2 silos. ...