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Lola, 2013 SCC 5), it nonetheless “is not impossible for the annuitant to determine to create rights under a written separation agreement between the annuitant and the annuitant’s common-law partner or former common-law partner relating to the division of property” – and that “such an agreement could be concluded at the time of separation, whether or not a common-law union agreement providing for the rights of each in the event of the union's failure had been previously signed.” ...

. … [T]he CRA will not require Form T2091 to be completed…. ...

In addition, according to the facts provided, the goodwill is not a depreciable property to which subsection 111(5.1) would apply …. ...

. … The fact that premiums paid to the RRSP prior to the time of death could not be deducted has no impact on the amount to be included. ...

In responding “generally, yes,” CRA indicated that where a non-resident taxpayer carries on a business in Canada through a permanent establishment, a failure to meet statutory deadlines will carry the associated statutory penalties – but that CRA will consider, on a case-by-case basis, requests under s. 223(3) and (3.1) for relief of the resulting interest and penalties. ...

Accordingly, its failure to meet statutory deadlines will carry the associated statutory penalties – but CRA will consider, on a case-by-case basis, requests under s. 223(3) and (3.1) for relief of the resulting interest and penalties. ...

Therefore, on the basis of the documents submitted, it is our view that the promissory note constitutes absolute payment and … pursuant to subsections 28(1) and 76(1) of the Act, the amount of the promissory note received in respect of the cattle and feed inventory should have been included in the taxpayer's income for the year of the disposition. ...

CCRA responded: Even if the withdrawal is not referred to as a "policy loan" under the terms and conditions of the policy, this does not mean that the withdrawal is not a "policy loan" …. ...

As stated in Shell, "[w]here an interest rate is established in a market of lenders and borrowers acting at arm’s length from each other, it is generally a reasonable rate… ". ...

Consequently … the amount to be included in the CDA will be $800,000, which is the proceeds of the life insurance policy ($850,000) received by the corporation as a result of the insured's death less the ACB of that policy to the corporation ($50,000) immediately before death. ...