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. … [T]he phrase “to or for an individual” in subsection 146.1(2.21) must apply in respect of a living individual and an EAP cannot be paid in respect of a beneficiary once the beneficiary in question is deceased. ...

. … If an executor, in performing the estate administration, is under an obligation to dispose of property or he exercises his power to dispose of the property… subsection 70(6) is not complied with since the property has not vested indefeasibly in the trust. ...

(b) of the CDA definition from the receipt of the dividend – so that Holdco can then pay a capital dividend of $1M to its individual shareholder. ...

(b) of the CDA definition from the receipt of the dividend – so that Holdco can then pay a capital dividend of $1M to its individual shareholder. ...

. … As well, the CRA will consider that a dividend recipient’s Part IV tax liability with respect to a dividend received from a connected dividend payer will be determined according to the dividend refund actually received by the dividend payer. ...

Standard Life took essentially the opposite approach to the interpretation of a similar requirement under s. 138(11.3) – so that it was necessary for the taxpayer to qualify as an "insurer" in the preceding taxation year rather than only in the current year, in order for an asset bump to be available. ...

(b) of 233.3(1) – “specified foreign property,” CRA stated: We wish to clarify that a specified foreign property can include inter alia tangible or intangible property…., real property can include… intangible property…[and] a mineral right would likely be considered an intangible property. ...

. … [A] taxpayer’s share of partnership income from a Canadian limited partnership is required to be included in computing its income for the year for purposes of [that] definition…. ...

These sourcing rules are generally set out in Folio S5-F2-C1 …. For the purposes of paragraph 7 of Article XXI of the Treaty, the CRA’s view is that “income” includes the taxable portion of a capital gain. ...

. …. [T]he comments of the Supreme Court of Canada on the considerations mentioned in previous paragraphs could still be relevant. ...