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. … The Corporation appears to be the particular qualifying person which has agreed to issue or sell the shares. ...

. … [T]he Taxpayer would need to demonstrate that the ship owner is operating the ship under the Taxpayer’s direction and not, in effect, under the direction of the Related Party Customers. ...

17 November 2015 Roundtable, 2015-0613821C6- TEI question on section 55-- summary under Paragraph 55(2.1)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) regular dividends not in excess of return on comparable listed shares not included/ "significant" measured in dollar or % TEI members remain concerned that, because all dividends result in a reduction of the fair-market value of shares held by the dividend payor and increase the cost of properties held by the dividend recipient, the CRA may try to reassess ordinary course dividends on the basis that a purpose of every dividend is a tainted purpose. ...

Internal Revenue Code (footnote 1 [Section 691(c)(1) provides that a person who includes an amount of income in respect of a decedent (“IRD”) in gross income under § 691(a) is allowed as a deduction, for the same taxable year, a portion of the estate tax paid by reason of the inclusion of that IRD in the decedent’s gross estate]), such excluded amount would not be taxable in Canada and may be deducted by the Canadian resident taxpayer in computing his taxable income in accordance with subparagraph 110(1)(f)(i). ...

. … [T]he services of the employee assistance program that are counseling or advice respecting areas other than those specified in clauses (A) and (B) of subparagraph 6(1)(a)(iv), would not come within the exception provided by paragraph 6(1)(a)(iv). ...

The Distribution will be considered to be received as a dividend in respect of a class of shares of capital stock of FA1 by the Taxpayers (Canco7, 8 and 9) for the purposes of s. 212.3(9)(b)(ii) – A(B). ...

. … [T]he CRA accepts that the shares being the subject to the potential operation of a [separate] PAC will not, in and of itself, negate the amount that was specified for the purposes of subsection 191(4). ...

Shareholder would have to maintain that PUC balance in € for the purposes of determining its CTRs. ...

. … [W]hen a foreign trust grants funds to other organizations…the recipient organization would have to be considered “charitable” according to Canadian common law.... ...

.), also owned 100% by them, which used the land exclusively in its farming business for the first 11 of the 20 years that the land was held by the partnership – but, then, apparently ceased operations. ...