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. … [T]he fact that there is an issuance of shares of the capital stock of a transferee corporation, after the distribution of the property of the distributing corporation has been completed, would not be relevant for the purposes of the application of the definition of "permitted exchange" in subsection 55(1). ...

Finally … to the extent that the control of the transferee corporation was not acquired by the family trust, subparagraph 55(3.1)(b)(ii) would also not be applicable. ...

After noting that “subparagraph 110(1)(d.01)(iii) provides that the gift must be made in the year and on or before the day that is 30 days after the day on which the taxpayer acquired the security” and that “A taxpayer who wishes to benefit from the deduction provided in paragraph 110(1)(d.1) must inter alia hold the securities … for a minimum period of two years,” CRA stated: [A] taxpayer who is only eligible for the deduction under paragraph 110(1)(d.1) will not be eligible for the deduction listed in paragraph 110(1)(d.01) because it will be impossible for the taxpayer to satisfy both the requirement of subparagraph 110(1)(d.01)(iii) and that of subparagraph 110(1)(d.1)(ii). ...

. … The following are some elements that may be considered by the CRA in determining the "normal rate of return" in a particular situation: The rate of return that the corporation could earn on the capital invested to acquire the property made available to its shareholder; The rate of interest on a loan that the shareholder would have received from a person with whom the shareholder deals at arm's length if the shareholder had borrowed personally to acquire the property made available to the shareholder. ...

. … [K]eeping in mind that what is being valued are conditions of a sale that are essential to the closing of the sale, the various elements that would have an impact on the income of the business sold must be evaluated in light of each individual situation. ...

We are of the view that a painting by a foreign artist that is owned by a public corporation and used exclusively to decorate a boardroom of that corporation is probably not personal-use property of that corporation …. ...

. … [A]s a matter of first impression, it cannot be assumed that a request for an extension of time under subsection 220(3.2) to file an election under subsection 184(3) would necessarily be denied in a particular situation similar to the given hypothetical situation. ...

. … [T]hat provision does not have the effect of allowing the annuitant of a RRIF to share with the annuitant’s deceased spouse or common-law partner the tax burden applicable to the annuitant because of the RRIF. ...

. … The [s. 53(2.1)] election generally allows the taxpayer to elect to reduce an amount that would otherwise be included in income pursuant to paragraph 12(1)(x), by reducing the adjusted cost base of the property in question by the amount so elected pursuant to paragraph 53(2)(s). ...

Where the matter instead has not been previously considered by the GAAR Committee, and the GAAR is likely going to be an assessment position, the TSO will refer the matter to Headquarters prior to issuing the proposal letter – so that it would generally only issue a proposal letter if Headquarters recommends GAAR’s application. ...