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Summary of 2024 Ruling 2024-1008821R3 F under s. 55(1) – distribution. ...

Regarding the payment of “interest” on any preferred shares held by members, this would constitute in substance a distribution of the cooperative’s profits to them and, thus, be offside – and indeed, the mere issuance by it of such shares would put it offside even if no such interest was paid. ...

Under s. 212.3(1)(b), the s. 212.3 rules apply to an investment made by the CRIC in a subject corporation if as part of the series of transactions that includes the making of the investment, Forco acquired control of the CRIC and at the time of the “investment”, the Forco shares represented 25% or more of the votes or value of the CRIC – with s. 251(5)(b) rights being taken into account for these purposes. ...

Summary of 2022 Ruling 2021-0911791R3 F under s. 55(1) – distribution. ...

Summary of 2024 Ruling 2023-0998291R3 F under s. 55(1) – distribution. ...

However, as the unanticipated fugitive emissions occurred within Bco’s pipeline transportation network, “Aco may be able to avail itself of the relief provided in subsections 211.92(6) and (7) … because such emissions would likely be due to extraordinary circumstances outside of the control of Aco.” ...

19 June 2025- 12:21am CRA indicates that the children receiving an intergenerational transfer may control the purchaser corporation indirectly or as trustees of a trust Email this Content Our 2025 STEP Roundtable page- which provides the questions posed, and summaries of the preliminary oral responses given, at the 2025 STEP CRA Roundtable held on Tuesday – is now available. ...

However, if the agreed amount was greater than the property’s capital cost so as to realize a portion of the accrued capital gain, then s. 12(12) would apply so as to deem the property to be real estate inventory that was not an “eligible property,” thereby rendering the s. 85(1) election invalid – so that the full accrued gain would be business income. ...

Summary of 23 April 2025 External T.I. 2024-1046391E5 under s. 127.46(1) – red seal worker. ...

Although the provinces may issue BRNs, Canada does not – hence the conclusion. ...