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. … It is … not required that the services be rendered to the payer, either the directors of the corporation (the employer) or the administrator of the settlement fund. ...

After quoting from Nassau Walnut to the effect that a late designation was acceptable where the situation “ does not raise the spectre of retroactive tax planning,” the Directorate stated: [I]f the CRA has the ability to reassess the Taxpayer’s Part I income tax return for year-end #1 pursuant to subparagraph 152(4)(b)(iii) with respect to its disposition of the … US shares … the Taxpayer’s late-filed designation request could be considered. ...

Furthermore …., under civil and common law, a partnership … is simply the relationship that exists between persons or partners who carry on a business in common for profit. ... We refer you to … Klein [which] stated: …[T]he partnership itself does not have the capacity to be indebted. The debt of the partnership is owed by the partners …. ...

23 June 2010 Internal T.I. 2010-0368161I7 F- 84.1-- summary under Paragraph 84.1(2)(b) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(b) s. 84.1(2)(b) inapplicable to individual’s transfer of ½ of Opco to Holdco (owned by 3 unrelated individuals) for note and non-voting pref Three individuals (A, B, and C) each held 1/3 of the shares of Holdco, and Holdco and another individual, D, each held ½ of the shares of Opco. ... [Thereafter] … the Purchaser … is controlled by a group of 4 persons consisting of A, B, C and D (the Final Group). ... Consequently, the deeming provision in paragraph 84.1(2)(b) could not apply …. ...

14 October 2011 Internal T.I. 2011-0410781I7 F- Repas fournis gratuitement-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) benefit from free meals delivered on-site Respecting a proposal that employees would receive a catered meal service during their shifts, CRA stated: [T]o the extent … the provision of free meals … primarily benefits the employees and not primarily their employer, … the value of that benefit should be included in computing the income of those employees. ...

., $1,800 = $1,000 + $800). Neal Armstrong. Summary of 20 January 2021 Internal T.I. 2019-0832211I7 under s. 126(1). ...

After quoting from Nassau Walnut to the effect that where the Minister changes the provision under which the taxpayer’s income is computed and the taxpayer then seeks a deduction under the new provision, that request “ does not raise the spectre of retroactive tax planning,” the Directorate then stated that here: [I]f the CRA has the ability to reassess the Taxpayer’s Part I income tax return for year-end #1 pursuant to subparagraph 152(4)(b)(iii) with respect to its disposition of the … US shares … the Taxpayer’s late-filed designation request could be considered. ...

…Paragraph 96(1)(a)[‘s] … presumption that a partnership is a separate person … does not apply for the purposes of section 152.... Furthermore …., under civil and common law, a partnership … is simply the relationship that exists between persons or partners who carry on a business in common for profit. ... The debt of the partnership is owed by the partners …. ...

29 February 2024 Internal T.I. 2023-0987941I7- Amendments to GAAR and Advance Income Tax Rulings-- summary under Subsection 84(2) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(2) CRA after the GAAR amendments will continue to rule on post-mortem pipelines complying with its published policies, but not on inter vivos surplus stripping by individuals Regarding the status of post-mortem pipeline transactions following the amended GAAR rule, the Directorate stated: The Directorate does not consider the use of a pipeline transaction as a means to preserve the capital gain arising on the death of a shareholder while limiting double taxation on the subsequent distribution of Opco’s assets to be a … [GAAR] abuse …. ...

29 February 2024 Internal T.I. 2023-0987941I7- Amendments to GAAR and Advance Income Tax Rulings-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) CRA will continue to issue post-mortem pipeline rulings following the GAAR amendments, but will not rule on surplus stripping by individuals Regarding the status of post-mortem pipeline transactions following the amended GAAR rule, the Directorate stated: The Directorate does not consider the use of a pipeline transaction as a means to preserve the capital gain arising on the death of a shareholder while limiting double taxation on the subsequent distribution of Opco’s assets to be a … [GAAR] abuse …. ...