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. … Our conclusion would be the same if the transactions respecting a freeze of Opco in order to introduce Nephew were part of the series of transactions that included the deemed dividend received by Holdco as a result of the redemption of the Class "D" shares of the capital stock of Opco held by Holdco, as Nephew and Nephew Inc. were related to Holdco, the dividend recipient, by virtue of subparagraphs 251(2)(b)(iii) and 251(2)(c)(ii), respectively. ...

. … Justice L'Heureux-Dubé seemed to suggest that Mara Properties stands for the proposition that subsection 88(1) deems the parent to have received property of the same character from its subsidiary upon the subsidiary's wind-up. ...

Proposed transactions The terms of the Notes A will be amended (but with no novation) to change the governing law and to add a right allowing the holder to exchange them for new Canadian-dollar interest-bearing demand notes ("Notes B"); and a similar exchange right into Canco1 Note B will be added to Canco1 Note A – with both exchange rights then being exercised by Canco3. ...

. … If the total of all the decreases exceeds the total of all the increases to the UCC of a class as of the end of a taxation year, subsection 13(1) provides that this excess shall be included in computing the taxpayer's income for the year. ...

(a)(i) of the "earnings" definition) – without duplication of the adjustments in 1 and 2. ...

. … [T]these entities have many characteristics in common with "limited liability companies" ("LLCs") that exist in the U.S., which are generally considered to be corporations for the purposes of the Act, but that they also have many characteristics in common with the various forms of partnerships.... ...

Response After summarizing the purpose requirement in Reg. 6205(2)(a)(i), and the requirement in Reg. 6205(2)(a)(i)(III) that each beneficiary not deal at arm's length with the Original Holder, and noting that each participating share would be required to satisfy Reg. 6205(1), and before noting the requirements of Reg. 6205(4)(c)(i) and (ii), CRA noted (Tax Interpretations translation) that, respecting the amalgamation, Reg. 6205(4)(c) " creates a presumption under which preferred shares issued by the New Corporation to each Original Holder qualify as a Prescribed Share. ...

" This could be the case given that the payment of the dividends may have fully accessed any available exempt surplus of CCo, whereas if there instead had been a sale of CCo shares to NR1 at a gain followed by a s. 93(1) election, the amount of exempt surplus which was accessed under the operation of Regs. 5902(1) and 5901 could be more limited – which would result in pre-acquisition surplus dividends grinding basis under s. 92(2) which, in turn, would result in a taxable capital gain which was foreign accrual property income. ...

. … If it is established on the facts that the taxpayer ordinarily occupied Residences 1, 2, and 3, the move from Residence 1 to Residence 2 is considered a relocation, and that from Residence 2 to Residence 3 as a second relocation. ...

Accordingly, Fund 1 will purchase currency forward contracts (the "Canadian Hedging Contracts") solely in respect of the Hedged Class, and: The Hedged Class … will have a return that is based on the performance of Fund 1's portfolio of investments without regard for the performance, either positive or negative, attributable to changes in value of the relevant foreign currency relative to the Canadian dollar because the foreign currency exposure of the portion of Fund 1 that is attributable to the Hedged Class will be substantially hedged using the Canadian Hedging Contracts. ...