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. … Subsection 15(1) could apply, for example, if at the time the loan is made by Aco, the other corporation (“Bco”) is unable to repay the loan and/or provide reasonable security, with the result that the value of Aco would be impaired. ...

(a)(i) to (iii) of the definition of NERDTOH in s. 129(4)- always correspond to the foreign tax deduction (FTD) otherwise claimed by the corporation under s. 126(1) in respect of its foreign non-business income, reduced by 8% of the foreign investment income (FII), even if no tax is withheld by the foreign country on such investment income – for example, on the sale of shares of a foreign public company listed on a foreign stock exchange resulting in a capital gain? ...

Summary of 10 October 2024 APFF Financial Strategies & Instruments Roundtable, Q.10 under s. 148(7). ...

Consequently [2013-0480361C6] … is still valid. ...

Taxpayers are expected to have full access to the information pertaining to their obligations or entitlements under the ITA – and to the extent these obligations are not met, CRA will exercise the powers under the ITA to enforce compliance with tax laws and maintain the integrity of the tax system. ...

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.. ...

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

In the situation you described … the allowance based on a rate of $0.44 per kilometer received by the employee should be included in computing the employee’s income by virtue of paragraph 6(1)(b). ...

. … However, the portion of such premiums that does not contribute to the increase of the cash surrender value of the Policy at that time will not be on hand at the safe income determination time and would therefore reduce the amount of safe income that could reasonably be considered to contribute, immediately before the Dividend-in-Kind, to the accrued capital gain on the Opco shares on which that dividend is received. ...