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CRA stated: It appears … that the sale of the shares of Holdco B and Holdco A by Holdco C takes place as part of the same series of transactions as the share redemptions …. While it might be reasonable to conclude that the deemed dividends … do not affect the fair market value of the Holdco A and Holdco B shares (and consequently any capital gain realized by Holdco C on its disposition of such shares), such dividends would reduce a portion of the capital gain that, but for such dividend, would have been realized on a disposition at fair market value of any shares (i.e., the shares of Realco and Opco). … … If the shares of Opco and Realco represent more than 10% of the value of Holdco A and Holdco B.. then … clause 55(3)(a)(iii)(B) and clause 55(3)(a)(iv)(B) will technically apply. …[P]aragraph 55(3)(a) is intended to provide an exemption from the application of subsection 55(2) for certain dividends received in the course of related-party transactions. … [S]ince the other direct or indirect shareholders of Holdco A are not related persons, and the transactions … include a sale of Holdco A shares as part of the same series as the deemed dividends … the application of subsection 55(2) is operating as intended. ...

. … … [T]he price adjustment clause … reduce[d] the redemption value of the Rollover Preferred Shares from $2,000,000 to $1,000,000…. [S]ubsection 191(4) would not apply … on the basis that no amount was actually and validly designated in respect of each of the Rollover Preferred Shares on the transfer of assets by Pubco to Subco, or on the basis that the amount originally designated in respect of each of those shares would exceed the fair market value of the assets transferred by Pubco to Subco. ...

. … … The Court concluded that the taxpayer would not have entered into the swaps if it had not acquired the US Operations. ...

. … … Tinhorn Creek …concluded that winemaking was linked to viticulture and was an integral part of the taxpayer's farming business. ...

Thus, a partner receiving undivided interests in shares held by a partnership in accordance with subsection 98(3) could be considered to hold shares of the corporation for the purpose of determining whether the recipient is entitled to the capital gains deduction …. … [T]he shareholder has held the undivided interests in the shares for more than 24 months and will continue to hold them until their disposition. ...

We consider those benefits to be "social assistance benefits" …. … The benefits are not solely for the benefit of an Indian resident on a reserve and are therefore not personal property of an Indian resident on a reserve and are therefore not exempt from taxation under [the Indian Act]. ...

Lola, 2013 SCC 5), it nonetheless “is not impossible for the annuitant to determine to create rights under a written separation agreement between the annuitant and the annuitant’s common-law partner or former common-law partner relating to the division of property ” – and that “such an agreement could be concluded at the time of separation, whether or not a common-law union agreement providing for the rights of each in the event of the union's failure had been previously signed.” ...

. … … [T]he question of whether a contract is a lease agreement or a contract of sale should be resolved on the basis of the legal relationships created by the terms of an agreement, rather than by an assessment of the underlying economic reality (as indicated by GAAP). ...

. … … It is CRA’s position that reforestation obligations in the forest industry and reclamation obligations in the mining and oil and gas industries are generally embedded in the related tenures or rights, as they cannot usually be severed and would therefore depress the value. ...

This Proof of Income can be viewed and printed by a taxpayer using the "My Account for Individuals" option …. … [W]ith respect to capital cost allowance that may have been claimed by a taxpayer in prior years, this information could possibly be included in the Proof of Income mentioned above. ...