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. … [C]ontingency is an essential element of a royalty. Words and Phrases royalty ...

The proposed transactions entailed the s. 85(1) transfer by him to a Newco of his Opco shares for notes in an amount close to the transferred shares’ hard ACB and preferred shares as to the balance – followed by an amalgamation (or wind-up) of the Opcos over a year later and gradual repayment of the notes on a redacted timetable. ...

Lola, 2013 SCC 5), it nonetheless “is not impossible for the annuitant to determine to create rights under a written separation agreement between the annuitant and the annuitant’s common-law partner or former common-law partner relating to the division of property” – and that “such an agreement could be concluded at the time of separation, whether or not a common-law union agreement providing for the rights of each in the event of the union's failure had been previously signed.” ...

. … [T]he CRA will not require Form T2091 to be completed…. ...

In addition, according to the facts provided, the goodwill is not a depreciable property to which subsection 111(5.1) would apply …. ...

. … The fact that premiums paid to the RRSP prior to the time of death could not be deducted has no impact on the amount to be included. ...

In these circumstances, the FMV of such work in progress of the designated professional at the end of the taxation year would be nil … [except where] it is possible, at the end of the year, to establish an amount that can reasonably be expected to be received after the end of the taxation year in respect of that work. ...

In responding “generally, yes,” CRA indicated that where a non-resident taxpayer carries on a business in Canada through a permanent establishment, a failure to meet statutory deadlines will carry the associated statutory penalties – but that CRA will consider, on a case-by-case basis, requests under s. 223(3) and (3.1) for relief of the resulting interest and penalties. ...

Accordingly, its failure to meet statutory deadlines will carry the associated statutory penalties – but CRA will consider, on a case-by-case basis, requests under s. 223(3) and (3.1) for relief of the resulting interest and penalties. ...

DC then transferred its marketable securities to three transferee corporations (TCs) for the three beneficiaries in consideration for “butterfly shares” – but with DC holding onto the notes that it received on the immediate redemption of the butterfly shares for a redacted period of time, after which DC was wound-up into the TCs, thereby resulting in deemed winding-up dividends and in the notes being extinguished on their being assigned to the TCs. ...