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. … [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. ...

. … The fact that a trustee guarantees bank loans made to the trust does not, in itself, give rise to the application of the provisions of subsection 75(2). ...

After finding that this credit was not required to be included in income under s. 12(1)(x.2), CRA noted that it: has taken the position in the past that the RDCL does not reduce cumulative Canadian exploration expenses ("CCEE") and cumulative Canadian development expenses ("CCDE"), on the basis that the RDCL was too remote from the Canadian exploration expense ("CEE") and Canadian development expense ("CDE") and therefore did not have a sufficiently direct connection to the CEE and CDE incurred by the particular corporation to fall within element J of the definition of CCEE in subsection 66.1(6) and the description of M in the definition of CCDE in subsection 66.2(5) …. ...

. … The fact of incurring a loss is the only real condition to be satisfied in order to claim an RDCL amount. ...

. … Subsection 98(1) will not apply where, the affairs of a partnership are wound up at any time during its usual fiscal period and all of the partnership's property is distributed prior to, or concurrently with, the winding-up. ...

. … [I]t seems difficult to argue that the parties intended to create a new contract. ...

. … Before finding that each of ss. 75(2)(a)(i) and (ii) and (b) applied, CRA stated: Given the settlor’s power to amend the trust and to remove any trustee, in our opinion the settlor is empowered in this case to unilaterally amend any provision of the trust indenture at their sole discretion. ...