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Content Provider which relates to the streaming of the digital content to Canco’s subscribers to the extent that the right in or to the use of the digital content is being used or reproduced in Canada” – except that: Canadian withholding tax can still apply, should the right in or to the use of the digital content be partly used or reproduced in Canada prior to being streamed to these foreign subscribers for viewing outside of Canada (but only to the extent of the payment that is related to the use or reproduction in Canada) or if it was being streamed in Canada. ...

Would this dividend be characterized as income that is derived directly or indirectly from a related business for s. 120.4 purposes – and would the answer change if the dividend was paid before 2018? ...

X's shares are “excluded shares” if such $100,000 of income was “derived from the carrying on of a business the purpose of which is to earn interest income and dividends … notwithstanding the fact that the capital used in the acquisition by Holdco of the property used in carrying on its business was derived from dividends received from Opco.” ...

However, CRA then stated: By virtue of subparagraph 120.4(1.1)(c)(ii), the amount that is Jeanne's income from property is deemed to be an excluded amount to the extent that the amount would have been an excluded amount in respect of an individual- Jean – who was, immediately before his death, Jeanne's spouse or common-law partner, if the amount were included in computing Jean's income for his last taxation year. ...

(c)(ii)(D) of the definition of "split income" depending on the level of involvement of Julien, but went on to indicate that even if this were the case, the exclusion in s. 120.4(1.1)(c)(ii) would appear to apply: By virtue of subparagraph 120.4(1.1)(c)(ii), the amount that is Jocelyne's income from property is deemed to be an excluded amount to the extent that the amount would have been an excluded amount in respect of an individual- Joseph – who was, immediately before his death, Jocelyne's spouse or common-law partner, if the amount were included in computing Joseph's income for his last taxation year. ...

. … HBP participants who withdraw over more than one year will generally be contacted by the CRA to confirm details of their participation. ...

. … Thus, as soon as a transaction creates legal impacts in a taxpayer's taxation year that are not otherwise statute-barred, the resulting tax consequences may be determined by the Minister. ...

. … The income of the Trust for the XXXXXXXXXX taxation year would be computed under Canadian rules pursuant to section 250.1 and would include the $XXXXXXXXXX dividends received. ...

After noting that such policy did not apply to cash equivalent gifts and awards, such as where the employee receives reward points, which are accumulated and can be redeemed for a choice of goods, CRA stated that there could be “arguments that the points may not constitute a cash or cash equivalent award … since the points cannot be converted into cash and the number of goods that the employee can acquire, in exchange for the accumulated points, is very limited.” ...

. … [I]f the trust continues to exist after deregistration and the shares of the cooperative are not transferred to the annuitant in the year of deregistration or are transferred in a year subsequent to the year in which subsection 146(12) applies, we are of the view that no withholding tax is required under the application of the provisions of the Act and Regulations since no payment is made on deregistration and in the year of deregistration. ...