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If the Brazilian affiliate had a chain of other foreign affiliates under it, that could also by reason of the chain rules result in the denial of FAT in respect of FAPI for those underlying subsidiaries – or for subsidiaries up above, as well. ...

10 October 2008 Roundtable, 2008-0285471C6 F- Fiducie étrangère exempte- fiducie admissible-- summary under Fixed Interest Summary Under Tax Topics- Income Tax Act- Section 94- Subsection 94(1)- Fixed Interest discretion as to payment timing is acceptable – but discretion in choice of record dates could affect beneficiaries’ respective shares Where the trustee of an investment trust has discretion as to the timing of distributions of income or capital without any discretion as to the share of income or capital distributable to each beneficiary, would such discretion result in the trust not being eligible under para. ...

The issue of determining the fair market value of shares owned by a person immediately before death and how to allocate the fair market value of a life insurance policy among different classes of shares is a question of fact …. ...

After noting the distinction between “loans and advances” and “all other indebtedness” in ss. 181.2(3)(c) and (f), CRA stated: "[I]indebtedness " has a broader meaning than the term "loans" since it includes not only the lender-borrower relationship but also a seller-buyer transaction. ...

CRA responded that in light of the amended s. 55(2)(c) wording and its understanding of the tax policy of s. 55(2), the amount deemed to be a gain under s. 55(2)(c) is deemed to be realized on the disposition of a capital property at the time of the payment of the dividend – for purposes of inclusion in income, but also for the purpose of the CDA definition. ...

21 November 2017 CTF Roundtable Q. 6, 2017-0724071C6- Circular calculations Part IV tax-- summary under Paragraph 186(1)(b) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(1)- Paragraph 186(1)(b) refunded Pt IV tax payable not reduced by application of s. 55(2) Holdco receives a dividend of $400,000 that is subject to Part IV tax of $153,333 (38.33% of $400,000) equalling the connected payer’s dividend refund and, in turn, pays a dividend to its shareholders resulting in a refund of the Part IV tax – so that the dividend received by Holdco is subject to s. 55(2). ...

CRA indicated that the issue here is whether the U.S. dollars received by the borrower under the new loan are identical property to the foreign currency that it was deemed to have disposed of under s. 39(2), and noted that under the "property" definition in s. 248(1), “money could constitute property unless a contrary intention is evident” – but then stated: However, the CRA's position is not to consider money to be identical property for the purposes of subparagraph 40(2)(g)(i) or subsections 40(3.3) and (3.4) in a circumstance such as this where a taxpayer sustains a loss under subsection 39(2). ...

. … A written copy of the individual’s election should be retained for future reference…. ...

The executor of a deceased annuitant's estate … should simply indicate the amount claimed in line 232 of the terminal return of the deceased annuitant and use the space to the left of the line to indicate that it is a deduction for the refund of unused RRSP contributions. ...

. … If the debt is a capital property, subsections 70(5), 70(6) and 73(1) could apply where all the conditions set out in those subsections are met. ...