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There is no provision in … the Regulations requiring an employer to make deductions in respect of the lump sum payment of a retiring allowance to a non-resident person. ...

6 May 2005 External T.I. 2005-0116981E5 F- Rollover under section 85 of an ECP-- summary under Paragraph 14(1)(a) Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(1)- Paragraph 14(1)(a) “exempt gains balance" is of no utility in calculating the amount to be included in income under … 14(1)(a)" Mr. ...

CRA stated: [A]s indicated in … IT-479R …[t]he CRA generally presumes that: (a) the gain or loss realized by a holder of options is on the same account as the holder's transactions in shares; (b) the gain or loss realized by a writer of covered options is on the same account as the underlying shares; and (c) the gain or loss realized by a writer of naked options is normally on income account. ...

After noting the distinction between “loans and advances” and “all other indebtedness” in ss. 181.2(3)(c) and (f), CRA stated: "[I]indebtedness " has a broader meaning than the term "loans" since it includes not only the lender-borrower relationship but also a seller-buyer transaction. ...

CRA stated that: Generally, a person is dependent on an individual if the individual provides for the individual's basic needs or necessities on a regular and consistent basis … [so that the taxpayer] cannot claim the wholly dependent person tax credit for dependants with physical or mental disabilities. ...

After noting that CRA has not relied on the comments in Sachs in relation to the preferred beneficiary designation that the "authority to pay income to beneficiaries … includes the authority to declare or designate income as held for them to the exclusion of the continuance of the trustee's authority to deprive them of it” to establish a position with respect to the term "payable" and referring to its comments in IT-286R2, para. 8, CRA stated: [A] written resolution signed by the trustees of a trust (or the minutes of a meeting of the trustees), whereby the trustees confer an irrevocable right on a beneficiary of the trust to receive a portion of the trust's income, is a means of establishing that the beneficiary has become entitled to enforce payment. ...

. … [I]t is quite possible that each of the Individuals and Newco were not dealing at arm's length. ...

CRA responded: … [T]he amount of the deemed dividend at the time of the purchase for cancellation of the shares of the capital stock of Canco on January 1, 2005 would be equal to the value of any consideration given by Canco and received by the Shareholder for the Shareholder’s shares of the capital stock of Canco at the time of the purchase for cancellation of such shares, including any covenants or promises to pay amounts in the future, that would be in excess of the paid-up capital in respect of such shares. ...

. … [I]f for a taxation year Mr. A decides to reduce the taxable capital gain to nil by claiming allowable capital losses, the tax consequences would be the same as those described in the previous paragraph for the purposes of the calculation under subsection 126(1). ...

. … [I]n a situation where an amount of money is donated to a school board by a donor for the purchase of books at the request of the donor for use by all students in a school community attended by a person related to the donor, it is our view that the donor will generally not receive an advantage. ...