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CRA was then approached, who determined that GAAR applied to the rollout of the Holdings shares to Holdco, so that s. 104(5.8) should be treated as applying to the capital property of Trust 2 upon the (now imminent) occurrence of the 21 st anniversary of the formation of Trust 1 so as to result in a deemed disposition of such property pursuant to s. 104(4)(b)(ii) – and the Directorate so ruled in this ruling letter. ...

. … The settlement amount paid to you was compensatory. As the Law Firm's services were acquired by you for consumption or use otherwise than in making taxable supplies for consideration, the conditions of subsection 169(1) are not met. ...

Aco then redeems the $100,000 of preferred shares (giving rise to a deemed dividend to Bco of that amount – which is not subject to s. 55(2) as Bco had full ACB in those shares), and BCo uses the redemption proceeds to discharge the note owing to A. ...

. … It does not mean that the place of activities must exist for a long time or be located in a durable building; for instance, a temporary field office on a construction site could be a fixed place of activities. ...

. … It does not mean that the place of activities must exist for a long time or be located in a durable building; for instance, a temporary field office on a construction site could be a fixed place of activities. ...

The parent of Holdco (“Canco”) then transfers shares of directly-held foreign affiliates (“FAs”) to Holdco in consideration for Holdco shares, and Holdco then transfers such FA shares to DC (and to Newco under s. 85(1)) in consideration for an increase to its membership interest in DC by an amount equal to the FMV of such transferred shares (and for the issuance of Newco shares – with Newco then dropping down its FA shares to DC in consideration for a correlative increase in its membership interest). ...

If the Fund had not acquired any additional units … the contribution to the Trust would not increase the Fund's ACB of its capital interest in the Trust, notwithstanding that it would increase the FMV of its capital interest in the Trust. ...

Parent makes a daylight loan to a partnership (New LP) formed by the Profitcos (Parent and two wholly-owned subsidiaries – Aco and CCo, with another wholly-owned subsidiary, BCo as the GP). ...

See summary under s. 55(1) – distribution. ...

BCo will transfer its business on a rollover basis to a newly formed subsidiary limited partnership (New LP) in consideration for the assumption of liabilities and the issuance of Class A units; and ACo will fund New LP from time to time in consideration for the issuance of Class B units (which are not described in the letter to have much difference from the Class A units – including equal per-unit allocations of income or loss- except as described below) at a subscription price equal to a valuation of the NAV per Class A unit and Class B unit. ...