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The percentage of relevant Canadian property for TCPCo is 100% (equal to $2 M / $2 M x 100). … [T]he percentage of relevant Canadian property for AusCo is 0% (equal to $0 / $10 M x 100). ... The proportionate value approach as described in 2015-0624511I7 can be summarized as follows: the percentage of relevant Canadian property of a particular subsidiary entity should be multiplied by the FMV of the shares of that entity; and the product resulting from above is the prorated FMV of the shares of the particular subsidiary entity which represents the FMV of a relevant Canadian property asset indirectly held by the parent. … [T]his would result in BVCo having a percentage of relevant Canadian property of 67% = $1 M / $1.5 M. Since more than 50% of the FMV of BVCo’s shares is derived from real or immovable property situated in Canada, the shares of BVCo are TCP …. ...

Regarding a bank loan received by Dco whose proceeds are used by it to make an interest-free loan to the LPs, CRA stated: [T]he comments in … S3-F6-C1, [paras. 1.54, 1.55] could apply in the partnership context …. ... Regarding the bank loan instead being made to Aco which uses the proceeds to directly or indirectly make an interest-free loan to the LPs (e.g., making such loan to Dco which, in turn, makes interest-free loans to the LPs, or to Bco, with back-to-back interest free loans made all the way down the stack), CRA stated: [I]n light of … Canadian Helicopters, the fact that the taxpayer's income is derived from dividends from stacked corporations should not be a factor that … prevents a taxpayer from relying on the direct use of borrowed funds exception to make an interest-free loan. [I]t would be necessary to assess … whether the interest-free loans made by Aco to the LP, Bco or Dco … affect Aco's ability to earn income. ...

X …. The Residence would therefore have been disposed of by [them to] Mrs. X …. Regarding the verbal agreement … it is up to the taxpayer to demonstrate the existence of such an agreement whose effect is to transfer the ownership of the Residence at a particular time other than on XXXXXXXXXX. If the taxpayers can provide evidence to you of that verbal agreement, you should consult … Legal Services …. ...

. … As indicated in paragraph 2.58 of … S1-F3-C2 … paragraph 45(1)(c) applies where the partial change in use of the property is substantial and of a more permanent nature. ...

. … Example 2 … Mr. A is present in Canada for 212 days in 2015, and the income of the partnership derived from his services is more than 50% of the gross active business revenue of the partnership ($200,000 / $350,000 = 57.14%) during those 212 days. ...

CRA responded: In general, a request for a revision to capital cost allowance claimed on property held by a partnership may be granted if all the conditions in paragraph 10 of … IC84-1... are satisfied by all members of the partnership. ... Such request will not be allowed … where … the Minister has issued a notice of determination … to one or more members. ...

19 November 2009 External T.I. 2007-0257251E5 F- Assurance-vie-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) s. 15(1) benefit where sub is policyholder and premium payer and parent is beneficiary – but not for reverse The parent corporation is the beneficiary of a life insurance policy while its subsidiary is the policyholder and pays the premiums. ... The above interpretation represents a change in position from …. 2004-006546 … and will apply as of calendar year 2010. … [W]here a parent corporation pays the premiums for a life insurance policy that it owns and of which the subsidiary is a beneficiary, there is no benefit to the shareholder under subsection 15(1). ...

. … IT-169 … addresses situations where the CRA determines that the FMV is higher or lower than the price otherwise determined by the parties to an agreement. Consequently … this Bulletin does not apply in this situation. [I]t is impossible … to comment as to its retroactive effect to the day of the initial transaction, since we do not have all the particulars …. [I]f it were appropriate to retroactively adjust the sale price, the CRA could apply subsection 152(4.2) in respect of taxation years already assessed … [but the] taxpayer must satisfy the five conditions for the CRA to agree to a reassessment giving rise to a refund. ...

After noting that this structure appeared to be intended to maximize the small business deductions by the five managementcos, CRA stated: According … Hughes Homes … 98 DTC 1082 … taxpayers have the burden of demonstrating that the fundamental reasons for the existence of the corporations are not tax-related. … [I]t seems unlikely that the corporate structure was put in place by the Individuals for reasons other than tax: … an operating corporation is created and used for each of the projects involving a real business risk; the payment of management fees to the management corporations instead of the payment of dividends (if the Operator had paid dividends, the management corporations would have been specified investment business corporations); … 4 out of 5 of the individuals are related by blood. ...

B cannot claim the children's amount in respect of any of her children since …she is not entitled to the wholly dependent person credit in respect of them and … none of the children ordinarily reside throughout the year with her and another parent. … [I]t is Mr. A who would be entitled to the child amount under paragraph 118(1)(b.1) for both children … since … he would be able to claim the wholly dependent person credit for his two children if paragraph 118(4)(a) did not apply to him for the year. … [U]nder paragraph 118(4)(a), Mr. A would not be able to claim the wholly dependent person credit in respect of more than one of his children …. ...