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In practice … we have found that CRA Appeals takes the position that the Appeals Branch has no authority to review a denied downward adjustment, and considers a notice of objection in which a denied downward adjustment is the only issue in dispute to be invalid. ...

. … Subparagraph 248(25)(b)(ii) contemplates that a person or partnership exercises discretion to make the other person or partnership beneficially interested in the particular trust, under either the terms or conditions of the particular trust or an arrangement in respect of a particular trust. ...

Also … Lyrtech RD…held that subsection 248(25) did not apply to paragraph 251(5)(b). ...

. … When subparagraph 256(1.2)(f)(ii), (iii), or (iv) applies to deem a person to own shares owned (or deemed to be owned) by the trust, two uncertainties arise. ...

. … Assuming there is no domestically defined permanent establishment in a province to which the sale is referable, the federal rate will be 25 percent plus a branch profit tax of 25 percent (asuming no treaty reduction) on the residual 75 percent unless reinvested. ...

. … Contrary direction in text that initial amounts already reflect other ITA provisions (p. 6) However, the language in the Proposed Amendments defines the “initial amounts” as amounts “that would be determined for the purposes of this Act (if this Act were read without reference to this section and section 245) in respect of the taxpayer or the partnership for a taxation year or fiscal period.” ...

. … [A] Canadian taxpayer that indirectly holds an interest in an LLC through a shareholder affiliate would be entitled to a deduction under 91(4) for tax paid by the shareholder affiliate in respect of FAPI earned by the LLC. ...

. … Double taxation for corporate LLC members until dividend (p. 18:27) [U]nlike individual members, corporate members are effectively subject to double taxation on FAPI inclusions until the income is repatriated. ...

. … Potential for taxpayers to direct where their tax refunds are paid (p. 9) This is a sensible, practical decision that points to the failure of section 116 to contemplate court-ordered sales of property. ...

On a subsequent sale by the trust of the shares to a third party, the QSBC definition would require that the shares have been owned by the trust, or a person related to the trust, for the prior 24-month period – and in this regard, s. 110.6(14)(c)(ii) provides that where a person who sold shares to a trust was related to all the beneficiaries, that person and the trust are deemed to have been related for the above purpose. ...