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In the 2020 Loss Year, Opco paid two taxable dividends of $200 each to its corporate shareholder, which it designated as eligible dividends – and then made an excessive eligible dividend designation in respect of each dividend. ...

Shortly after the end of the fiscal period, the limited partnership should make a distribution payable to the partner which is equal to amount of the loans received by the partner in the fiscal period, and the distribution should be used to fully settle the loans – in other words, CRA needs to see a set-off of the loans and the distributions. ...

Re (ii), CRA noted that s. 94(2)(g)(iv) provides that the loan to the beneficiary involves the acquisition by the trust of the debt entailing a deemed transfer by the debtor – so that, here, there is a deemed transfer of property from the beneficiary to the trust. ...

The Minister could, however, assess the resident beneficiary for an amount not exceeding $100,000 on December 31, 2022 given that the conditions in s. 94(7) were by assumption satisfied for the 2020 year – and this was so even if s. 94(3) had ceased to apply to the trust for its 2021 or 2022 taxation year. ...

IX(3) of the Canada-Barbados Treaty apply to preclude Canada from assessing Canco to increase its profits pursuant to ITA s. 247(2) (a “Primary Adjustment”) given that the five year period had passed – but also being mindful that BarbadosCo was an enterprise referred to in Art. ...

S. 104(24) would be satisfied if the full $350,000 was paid to her in cash, and also would be satisfied through the estate issuing the demand note “to the extent that the issuance of the note was permitted by the will and … the demand note was unconditional.” ...

. … [and] that a legal obligation to pay under contract does not exist until all contractual preconditions to which the payment relates are fulfilled [citing Wawang Forest Products]. ...

Regarding the notes that could be issued and transferred pursuant to the Right of Redemption, the ruling letter stated: It is expected that the maturity date for [such] Notes … will be XXXXXXXXXX years from the date of issuance, and in any event, will not exceed XXXXXXXXXX years from the date on which they are issued. ...

Accordingly, it was proposed that Aco Amalco would purchase the Xco shares of Eco Amalco (which would be problematic under s. 55(3.1)(c) if this occurred as part of the same series of transactions as the Sequential Butterflies) and that Xco would redeem the shares of Dco Amalco, including through the application of share subscription proceeds received from the holding company for the son of A (which would be problematic under s. 55(3.1)(d), as expanded by s. 55(3.2)(e), if part of the same series) – so that Xco would now mostly be owned by the two A-family companies. ...

Situation (b) The same as Situation (a) except that a holding company (HC), resident in a non-treaty country, was interposed for non-tax reasons between Foreign MNC and FE – but with the funding for the acquisition of the Canco shares still having come from Foreign MNC, and with any dividends paid flowing up to Foreign MNC. ...