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Regarding the first point, she noted that the redemption amount was not required by s. 181(5) to be paid “exclusively” or “primarily” in the course of a commercial activity, and stated (at para. 26): Unlike the words exclusively and primarily, the phrase “in the course of” has a broad meaning; it means “incidental to” or “connected to” directly or indirectly …. ...

. … [The 2021] notices of objection have not been adjudicated. In light of these circumstances, quashing the Minister’s decision to reassess may therefore have the practical effect of ordering the Minister to reconsider her decision. ...

., acquiring the FMO units at a high cost in steps 2 and 4, being allocated a capital gain by FMO in step 6 so as to generate a CDA increase which could then be distributed, and having their high cost FMO units redeemed in Step 7 so as to generate a capital loss to offset the capital gain in step 6) and “the only purpose for the appellants’ participation in the series of transactions was to pay capital dividends to their parent corporations and to avoid Part III tax in doing so” (para. 202) – and there accordingly was an avoidance transaction. ...

. – whereas here the taxpayers had substantiated the existence of an RCA by obtaining an actuarial report to support the amount of contributions necessary to provide them with a reasonable pension on retirement. ...

In concluding on this issue, she stated (at para. 97): … RBC does not hold, and indeed has never held, an interest in the Buchan field. ...

This registration-date issue was not resolved until over three months later, when CRA changed the effective date of the registration to August 1, 2012. 353 then refiled the returns for those earlier reporting periods during which it previously had not been registered, and on November 7, 2017, CRA assessed 353’s returns – but apparently not the initial three quarters. ...

She stated (at para. 133) that “the minimum beneficiary condition might also be satisfied through a unitholder transferring units to others” and (at para. 145) that she was satisfied that, in the context of the ITA, "’hold’ is intended to mean ‘own’, unless the context in which it is used indicates otherwise” – which was not the case regarding Regulation 4801. ...

. … The applicant derived the first two instalments as income when, in January 2008, they were paid, with his agreement, to the FTA by GI on his behalf. ...

The Queen, 2022 TCC 68, rev'd 2024 FCA 42-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) circular use of capital dividends abused the purpose of the CDA Following preliminary transactions, on June 28, 2004, a Canadian holding company (“Micsau”) held all the shares, having a fair market value (“FMV”) and adjusted cost base (“ACB”) of $101.8M and $48.1M respectively, and a nominal paid-up capital (“PUC”), of a holding company (“3295940”), which held a minority shareholding (having an FMV of $88.5M and an ACB of $4M, reflecting the crystallization of the safe income on hand of such shares, and a nominal PUC) in another holding company (“Holdings” – which was majority-owned by an non-resident arm’s length investor), which carried on a Canadian generic-pharmaceuticals business. ...