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On December 31, 2016, Opco had accumulated $100,000 in after-tax profits and safe income, As there were 200 outstanding AA and X shares, the X class shares had a redemption value on January 1, 2017 of $50,100 (($100,000 x 100/200) + $100 of PUC) On January 1, 2017, Opco paid a dividend of $50,000 to Holdco. ... After noting the Robertson rule that “income will be attributable to a particular class of shares in the same ratio in which each class would be entitled if all earnings of the corporation, but not share capital, were to be distributed,” CRA stated: [G]iven that…the Class X and AA shares were entitled to an equal share of Opco’s profits following the issuance of the Class X shares and that the value of the shares of each class would increase due to this share of profits, … the safe income earned or realized annually following the issuance of the Class X Shares could be proportionately allocated based on the number of shares of each class. ...

The safe income reasonably contributing to the capital gain on the 25 common shares of the capital stock of OPCO held by Trust A and Trust B is $59,940 (149,975 / 249,875 X 99,900) and the safe income reasonably contributing to the capital gain on the 100 preferred shares held by Trust A and Trust B is $39,960 (99,900 / 249 875 X 99,900). ...

., the taxation year in which the Trust's taxation year ends …. [S]ince Holdco is a beneficiary of the Trust at the time the $5,000 became payable to Holdco, the condition in paragraph 104(19)(b), that Holdco be a beneficiary of the Trust in the Trust's taxation year, is satisfied. ... If the Trust makes a s. 104(19) designation of the amount of the taxable dividend for its taxation year ending December 31, 20X1, Holdco will be required to include the dividend income in computing its income for its taxation year ending September 30, 20X2 and will be subject to s. 186(1)(b) for Part IV tax purposes – or if the Trust does not make the designation, such amount will not be a taxable dividend and Holdco will not be subject to Part IV tax on the $5,000.. ...

However, after taking into account [Reg.] 5900(3) …, since in computing the income of CFA1 and CFA2 FP is treated as if it were a separate person resident in Canada, subsection 91(5) of the Act would apply to permit a deduction by FP of the Foreign Dividends received by FP with the result that, with respect to such Foreign Dividends, there is no net income from property that would be included in the value of "A" in the definition of FAPI with respect to CFA1 and CFA2. ...

In the context of there having been an amalgamation, s. 87(2)(z.1) provided that if a capital dividend were paid by a predecessor corporation and a portion thereof would be deemed to be a taxable dividend by s. 83(2.1), the CDA of the predecessor corporation is not transferred to the amalgamated corporation – so that it would thus be necessary to determine whether all or substantially all of Corporation A's CDA, immediately before the payment of such a dividend, could reasonably be considered to consist of amounts not described in paras. ...

. … It should be noted that the totality of the interests of a partner held in a partnership constitute a single property of the partner and represent its interest in the partnership for purposes of the Act. ...

. … Similarity the fact that the Canadian company continues to collect the accounts receivable without notifying the various debtors would tend to indicate that a transfer of title has not actually taken place. ...

. … Specifically, however, repayments of a temporary nature (for example, certain cash pooling arrangements) may be evidence of a series of loans and repayments. ...