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In this regard, it is important to note that it is not necessary for such advice to result in an actual acquisition or disposition for the fees paid for such advice to be deductible (see document # E 9607657). ...

. … [A] taxpayer cannot use this method to meet the traceability/linkage test if tracing can be done. ...

In finding that such amount would not be included in determining the corporate beneficiary's safe income or safe income on hand, CCRA indicated “that ‘safe income’ in respect of a share of a corporation means the net income of the corporation, determined in accordance with the Act and adjusted by paragraph 55(5)(b), (c) or (d) … that is attributable to that particular share during the holding period” so that, as the amount distributed to the corporation would not be included in its income by virtue of the operation of s. 104(13.1), such amount could not be included in its safe income. ...

The Directorate indicated that this question turned, having regard to s. 248(3)(f) and its stipulation that in Quebec that property in which a person has a right of ownership is deemed to be beneficially owned by the person, on “whether [their] share transfer agreement … resulted in a transfer of ownership of Monsieur's shares to Madame for the purposes of the Civil Code of Quebec” and that, if so, “the share transfer agreement will also have had the effect of changing the beneficial ownership of the shares for the purposes of the definition of ‘disposition’ in subsection 248(1).” ...

In its recitation of the facts, CRA accepted that by virtue of an election by the Trust pursuant to s. 107(2.001), s. 107(2.1) applied to this distribution, so that Trust realized deemed proceeds of $1,200.000 (resulting in a taxable capital gain of $99,950 being allocated to each Beneficiary under s. 104(21)), each Beneficiary was deemed to have acquired 100 shares at a cost of $200,000, and each Beneficiary disposed of the beneficiary’s capital interest in the Trust for proceeds of $100, which under s. 107(1)(a) had a deemed ACB equal to the cost amount of the distributed shares of $100 – so that no gain was realized on the disposition of each such capital interest. ...

In addition, the amount by which the FMV of the policy included pursuant to s. 15(1) exceeded the cash surrender value was to be included in the ACB calculation – so that the policy’s ACB consequent on the transfer would be equal to the FMV of the policy. ...

. … It appears to us that in the circumstances you would be justified in considering that Mr. ...

CCRA noted that where there was not a new plan, then it would be possible for individuals who eventually receive disability insurance benefits to deduct the contributions made in the years prior to the event – but if there was a new plan, they would only be able to deduct their contributions since the start of the new plan. ...

Pursuant to s. 70(5.3), in determining the FMV of the deceased's shares, the FMV of the policy is its CSV under s. 148(9), which is to be determined without regard to any policy loans – so that such policy’s FMV would be equal to the full FMV of $1 million. ...

The Directorate stated: [U]nder the terms of subsection 231.5(1) … where, pursuant to sections 231.1 and 231.2, electronic records (such electronic records being "records" within the meaning of the definition of "record" in section 231 and the definition of "record" in subsection 248(1)) are being audited or reviewed or produced, the person who is doing the auditing or reviewing, or to whom the production is made, or any CCRA official, may make or cause to be made electronic copies of them. ...