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It could, however, assess the resident beneficiary for an amount not exceeding $100,000 on December 31, 2022 given that the conditions in s. 94(7) were by assumption satisfied for the 2020 year – and this was so even if s. 94(3) had ceased to apply to the trust for its 2021 or 2022 taxation year. ...

. … Even if a grant of full-value RSUs was related to past services, it is also still possible that those past services were rendered solely in the Grant Year. ...

S. 104(24) would be satisfied if the full $350,000 was paid to her in cash, and also would be satisfied through the estate issuing the demand note “to the extent that the issuance of the note was permitted by the will and … the demand note was unconditional.” ...

The unwinding of the above loss consolidation arrangements will entail inter alia Newco redeeming its preferred shares with a note, which New LP will use to repay the New LP Loan by assigning it to Parent, with that note then being set off against the Parent Loan – and Newco and New LP being wound up. ...

After noting that “on July 22, 2022, the Minister of Crown-Indigenous Relations announced that the section 87 tax exemption would be available for continuation on modern treaty governments’ former reserves and other First Nations reserves in Canada for prospective and existing modern treaty government beneficiaries who are registered or entitled to be registered under the Indian Act ”, CRA stated: [W]e agree with updating the Guidelines to allow modern treaty governments or organizations controlled by modern treaty governments to be eligible employers under Guideline 4. ...

4 June 2024 STEP Roundtable Q. 8, 2024-1007841C6- Disposition of Property Held in a Bare Trust-- summary under Subparagraph 150(1.1)(b)(ii) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.1)- Paragraph 150(1.1)(b)- Subparagraph 150(1.1)(b)(ii) a disposition by a bare trust, or the trust’s winding-up, generally is not a disposition under the ITA A bare trust (not described in (a) to (e.1) of s. 108(1) – trust) holds no property in the year other than a Cdn.$10,000 government bond and money, not exceeding Cdn.$50,000 in the year, so that it satisfies s. 150(1.2)(b). ...

Although the ordinarily-inhabited condition under the principal residence definition would not generally be met for the Secondary Suite while being rented to third parties, where it was subject to the s. 45(2) election it could nonetheless qualify as the taxpayer’s principal residence for up to four taxation years during which the election remained in effect – so that the homeowner would be able to choose for such a year to designate the Secondary Suite rather than the balance of the property as that taxpayer’s principal residence. ...

., the actual capital cost grossed-up to $15,000,000 and multiplied by the 50% Class 43.2 rate); It claims the Nova Scotia Capital Investment Tax Credit (“NS CITC”) of 25% of the $10,000,000 capital cost, or $2,500,000 and receives it by way of credit or refund; It claims and receives the Clean Technology Investment Tax Credit (“Clean Tech ITC”) pursuant to s. 127.45, which is calculated as 30% of the capital cost, as reduced by the NS CITC, viewed as government assistance that it can “reasonably be expected to receive” (on December 31, 2024, receipt of the NS CITC is contingent on it receiving, by its filing-due date, an entitlement certificate); It claims an Atlantic Investment Tax Credit (“AITC”) pursuant to s. 127(9) of $750,000, being 10% of the capital cost, again reduced to $7,500,000 by the NS CITC “government assistance” – and receives the AITC by way of credit against federal tax payable in the current year or during the carryforward or carryback period. ...

The two deferred payments were not made on the agreed dates because of disagreements about the method for their computation. 21 months after the closing date, the parties agreed that a deferred payment of $50,000, rather than $200,000 + $300,000, would be paid. ...

Further … a personal guarantee of the amount owing under a vendor take-back promissory note by the controlling shareholder of the purchaser corporation would not, where the purchaser corporation has the capacity to make the scheduled payments under the promissory note (and absent any other factors indicative of de facto control), result in the holder having de facto control of the purchaser corporation. ...