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Therefore, all facts must be analyzed to determine whether a portion of an amount allocated to a beneficiary of a trust is split income …. Where, in a particular taxation year, a portion of an amount included in the income of a beneficiary of a trust by virtue of subsection 104(13) satisfies the conditions for the application of clause (c)(ii)(C) … while another portion does not satisfy those conditions … only that portion of the amount that meets [those] conditions … must be included in the calculation of split income for that beneficiary. ...

CRA responded: [Under] paragraph (a) … of "excluded property" … [t]here must in particular be income from its business, rather than more generally "income from an active business" as that term is defined in subsection 95(1). … [T]he following should be considered in particular: the use that is actually made of the property in the course of the various activities of the FA, the income from the use or possession of the property, the intention of the FA with respect to the use and holding of the property, the terms and conditions of ownership of the property, the nature of the activities of the FA and current practices in the particular industrial sector. ...

. … [T]he excess portion … would not reduce the subsequently-computed CDA of the corporation that paid the dividend. Furthermore, subject to an election under subsection 184(3), paragraph 83(2)(b) results in no part of a dividend that is the subject of an election made under subsection 83(2) being included in computing the income of any shareholder. … [A]ny corporate shareholder would add to its CDA the entire dividend designated under the subsection 83(2) election (including the excess of the dividend on the capital dividend), provided that the dividend payor has not made an election pursuant to subsection 184(3). ...

The above comments should be considered whenever there is a conversion … to U.S. limited liability partnerships or U.S. limited liability limited partnerships…. … The CRA remains open to … an advance income tax ruling request…. ...

After finding that s. 15(1) might apply to the sale, the Directorate stated: Subsection 246(1) would apply … to the extent that Opco conferred on X, directly or indirectly and in any manner whatever, a benefit and to the extent that the value of that benefit would be included in computing X's income if it were a payment that Opco had made directly to X. In that regard, it appears that if Opco had made a payment directly to X, that payment would, inter alia, have been required to be included in computing X's income pursuant to …, paragraph 6(1)(a). Thus … the value of the benefit that Opco conferred on X would be included in computing X's income under paragraph 246(1)(a). ...

In summary, for the purpose of Article 5(3)(b) … the term “six months” generally means the aggregation of the number of days in six months … [being] 183 days …. ...

X satisfied the active engagement condition with respect to Opco’s business, and further finding that if “Holdco will pay the Dividend to Child X out of the funds from the $100,000 dividend received from Opco or from any dividends previously received from Opco, then … the Dividend would thus have come, directly or indirectly, from a related business- that of Opco- in respect of Child X.” so that the Dividend would be added to the split income of Child X, unless it constituted an excluded amount by virtue of another exclusion, CRA then stated: [I]f it can be determined that Holdco will pay the Dividend to Child X out of its after-tax income from its stock market investments, then that dividend would be an excluded amount for Child X and would not be included in calculating the child’s split income. ... On the other hand, if it were determined that Holdco does not carry on a business, then the Dividend would also be an "excluded amount" in respect of Child X by virtue of subparagraph (e)(i) of the definition … [since] there must be … a business carried on by an entity. … Based on the foregoing, Holdco must adequately monitor its funds derived from stock market investments in order to determine whether those funds were used to pay the Dividend. ...

6 October 2008 External T.I. 2008-0271421E5 F- Terres à bois-plan d'aménagement forestier Québec-- summary under Farming Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Farming woodlot, to be a farm, must focus on the fostering of the stand Before describing the requirements for a rollover under s. 73(3) (or 70(9), CRA noted the distinction in IT-373R2, para. 14 (approved in Desrosiers Estate) between a woodlot operation that was a farm (entailing “planting, nurturing and harvesting trees pursuant to a forestry management … plan and significant attention … paid to manage the growth, health, quality and composition of the stands”) and a logging operation, and that if the correspondent’s statement that “the land was used principally in a logging business” was correct, then the rollover would not be available. ...

CRA responded: [F]or [s. 164(6)] to apply, the legal representative must dispose of the capital property of the estate or all of the depreciable property of a prescribed class … within the first taxation year of the estate. … Furthermore …[t]he COVID-19 Time Limits Act temporarily enables the Minister responsible for the application of a federal Act … to suspend or extend certain time limits … for a maximum of six months, by order. ...

(c) of the definition of “excluded entity” in s. 18.2 is that “all or substantially all of the businesses … and undertakings and activities of the taxpayer are … carried on in Canada.” ... In this scenario – where Canada maintains full ability to tax – are the businesses, undertakings and activities of B Co carried on in Canada? ...