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. … The CRA has already concluded in some of these types of cases that avoidance transactions are caught by subsection 245(4) and that the general anti-avoidance rule applies. ...

After noting that in the absence of an s. 89(11) election, Corporation B became a CCPC on June 1, 20-A, CRA stated: [As] Corporation B did not make an election under subsection 89(11) to not be a CCPC until November 14, 20-B … the exception in paragraph (d) of the definition of CCPC in subsection 125(7) could only apply to Corporation B for the taxation year beginning on June 1, 20-A and ending on May 14, 20-B, and thereafter... ...

In general … the exception in paragraph 55(3)(a) would appear to apply in respect of deemed dividends resulting from the cross-redemptions between Holdco Inc. and Holdco 2 Inc. ...

. … The GST, HST, QST or provincial tax portion, if any, of the amount paid should not be reported on the T4A slip since it is not an amount under subsection 153(1) and is not required to be included in computing the recipient's income under the Act. ...

. … [T]he CRA will examine any situation that involves a corporate group and where the life insurance proceeds included in a corporation's capital dividend account is not reduced by the adjusted cost base of the policy. ...

. … [T]he CRA will examine any situation that involves a corporate group and where the life insurance proceeds included in a corporation's capital dividend account is not reduced by the adjusted cost base of the policy. ...

. … [W]here a source of income exists, either property or business income, reasonable training expenses incurred by a taxpayer to earn income from that source are generally deductible to the extent that they do not produce a lasting benefit to the taxpayer. ...

The Directorate stated: [C]adastral lots are considered, for the purposes of the Act, to be separate real property …. ...

CRA noted that, by virtue of s. 55(2.2) the amount of the dividend (which otherwise would be $1) would be deemed to be $700,000 for purposes of s. 55(2) to (2.4) – and given that the safe income on the Class A shares would be reduced by $700,000 under s. 55(2.3)(b), the ACB of the preferred shares also would be $700,000. ...

. … [T]he only significance of the fact that the penalty is assessable in respect of Year X and not Year X+7 is… the de minimis rule in paragraph 247(3)(b)…. ...