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. … Where business expenses have been paid by someone other than the taxpayer carrying on the business, the amounts so paid could, depending on the circumstances, be included in the income of the taxpayer's business or give rise to the application of section 80. ...

Pursuant to s. 70(5.3), in determining the FMV of the deceased's shares, the FMV of the policy is its CSV under s. 148(9), which is to be determined without regard to any policy loans – so that such policy’s FMV would be equal to the full FMV of $1 million. ...

A had been actively engaged on a regular, continuous and substantial basis for many years – but Mr. ...

CRA stated that although “the excess of PUC over ACB of the shares of DCco … could imply that the shareholders may have realized a bargain purchase of the tax attributes of the assets of DCco,” however: [S]nce the main concern of paragraphs 55(3)(a) and 55(3)(b) is to allow for a tax-free reorganization, the CRA would not attempt to challenge a reduction of PUC on the shares of DCco that are held by TCco prior to their redemption where the potential gain on the shares of DCco is transferred to the shares of TCco that are held by the shareholders, i.e., where the PUC and ACB of the shares of TCco held by the shareholders are equal to the PUC and ACB respectively of the shares of DCco held by the shareholders at the beginning of the series of transactions. ...

Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them If a U.K. resident disposes of shares of its Canadian subsidiary that derive the greater part of their value from rights related to an active oil and gas business, is the gain on the disposition exempted under para. 7? ...

Example 2 The fact that another entity owns the shared workspace is not important to the PE analysis – it is enough that the shared workspace is at the non-resident’s disposal. ...

XXIX A(3) – the US is engaged in the active conduct of a trade or business in the U.S.; the income is “derived from [Canada] in connection with, or incidental to, that trade or business (including any such income derived directly or indirectly by [the U.S. resident] through one or more other [Canadian residents] (the “connected test”); and the trade or business carried on in the U.S. is substantial in relation to the activity carried on in Canada giving rise to the income in respect of which treaty benefits are claimed- the connected test will not be satisfied. ...

After noting that the “rules in section 306 … apply on a policy-by-policy basis and require actuarial calculations and information that only the issuing insurer will possess,” CRA responded: A life insurance policy issued by a non-resident insurer is not specifically precluded from qualifying as an "exempt policy" and thus, such a policy could qualify provided the criteria in section 306 of the Regulations are satisfied. ...

. … Under paragraph 148(7)(b), Employee B will be deemed to have acquired the policy at a cost of $50,000 (which is the amount determined under paragraph 148(7)(a)). ...

., the work and energy that the individual devotes to the business and the nature of the business itself – so that, the more an individual is involved in the management and/or current activities of the business, the more likely it is that the individual will be considered to be actively engaged. ...