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. … What constitutes appropriate documentation depends on the specific facts and circumstances, but may include: non-consolidated financial statements of the foreign affiliate, trial balance of the foreign affiliate, complete minute books of the foreign affiliate, income tax returns and all relevant supporting schedules for the income tax returns of the foreign affiliate, support for income tax paid by the foreign affiliate, and relevant supporting documentation: describing the business(es) of the foreign affiliate, related to the nature of the income earned by the foreign affiliate, related to transactions involving the foreign affiliate, and related to dividends paid or received by the foreign affiliate. ...

It was “Rulings’ view that allowing subsection 220(2.1) to waive a taxpayer’s requirement to file an election not listed in Regulation 600 would negate the specific intention of Parliament in limiting late elections to only those that are prescribed in [Reg.] 600” – and, in any event, the CIF provision was not a provision of the Act itself, as required by s. 220(2.1). ...

It was “Rulings’ view that allowing subsection 220(2.1) to waive a taxpayer’s requirement to file an election not listed in Regulation 600 would negate the specific intention of Parliament in limiting late elections to only those that are prescribed in [Reg.] 600” – and, in any event, the CIF provision was not a provision of the Act itself, as required by s. 220(2.1). ...

CRA indicated that any income or loss from the portfolio X investments, or property substituted therefor, would be deemed to be the income or loss of Spouse A, and any taxable capital gain or allowable capital loss from the disposition of such investments or property substituted therefor will be deemed to be the taxable capital gain or allowable capital loss of Spouse A – for so long as such property continues to be held by the trust, and while Spouse A is resident. ...

. … [U]nless the Dependent Beneficiary is the person legally entitled to the surplus income a trust will not qualify as an LBT as there is the possibility that a person other than the Dependent Beneficiary can receive or obtain, during the Dependent Beneficiary’s lifetime, the use of the income of the trust. ...

However, practical solutions to these types of technical issues exist and therefore the CRA does not consider that a flexible approach is necessary in the[se] circumstances …. ...

Thus, it is our view that the amount will not be included in the borrower’s income …. ...

X did not wish his four children- who along with his wife and a family company were the beneficiaries of an inter vivos trust (“Trust 1”) holding shares of family companies – to be distributed the assets of Trust 1 (such shares) immediately before the 21 st anniversary of the settling of Trust 1. ...

(a), the joint designation referred to therein was required to “be made jointly by the deceased annuitant's legal representative and the Spouse” so that “in order for the designation to be valid, the Spouse must be alive at the time the joint designation is made,” and so that a “joint designation made … [with] the deceased Spouse's legal representative would not satisfy this requirement.” ...

CRA indicated that it had the discretion to grant a request to reduce the carrybacks so as to eliminate the GRIP reduction and associated Part III.1 tax (so that it might grant such request if it was satisfied that this was “a situation involving a bona fide error and not amounting to retroactive tax planning) provided that the loss years (2019 or 2020) were not statute-barred and that the request to reduce the carryback satisfied “the conditions … in subparagraphs 152(4)(b)(i) and 152(4.01)(b)(i) in respect of the [prior] Years.” ...