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CRA noted that, by virtue of s. 55(2.2) the amount of the dividend (which otherwise would be $1) would be deemed to be $700,000 for purposes of s. 55(2) to (2.4) – and given that the safe income on the Class A shares would be reduced by $700,000 under s. 55(2.3)(b), the ACB of the preferred shares also would be $700,000. ...

. … [T]he only significance of the fact that the penalty is assessable in respect of Year X and not Year X+7 is… the de minimis rule in paragraph 247(3)(b)…. ...

LLC that is a foreign affiliate and has a single member which is a regarded U.S. corporation should compute its “earnings” in accordance with Reg. 5907(1) – earnings- s. ...

. … Where a taxpayer and the taxpayer’s ex-spouse or former common-law partner state that they are living at the same address, but consider themselves as merely roommates from the date of separation, the following documents may support a request for validation: Divorce document; A court order or a legal separation agreement that sets out legal details of the arrangements for the individuals, child custody and provision for child support; Other legal documents; Mortgage documents showing the assumption of the entire mortgage by one of the parties and the effective date of the change; Proof of individual vehicle loans indicating the effective date of the change, if applicable; Proof of automobile insurance for each former spouse or common-law partner indicating the effective date of the change (from family to individual); Proof of individual medical insurance indicating the effective date of the change or the date the spouse or common-law partner was removed from the client's file; Individual credit card statements indicating the effective date of the change, if applicable; Letter from an independent third party, supplemented by persons in authority, attesting that the two individuals live at the same address but live separate and apart and no longer appear as a couple since a certain date. ...

. … If a gain were to result, an amount in respect of tax, or acceptable security, would be required to be remitted. ...

. … [However] section 7… will not apply to situations where an employer contributes an amount to a trust and the trust uses the funds to acquire shares through open market transactions. ...

However, recognizing an upstream loan would result in double counting because the assets acquired by the parent out of the proceeds thereof would already be counted for purposes of the tests – so that the loan’s value decreases the relevant FMV of the shares of the particular wholly-owned subsidiary. ...

. … Subject to the examination of the trust indenture, it would appear according to the two described scenarios that the interest of each of the beneficiaries is to be terminated as a consequence of a distribution of property of the trust to the beneficiary or his estate. ...

However, an analysis of all the relevant facts and documents would be required …. ...

. … [T]he NRCan Guide indicates that expenses for eligible property incorporated into a ground source heat pump system that qualifies for Class 43.2 treatment (by virtue of subparagraph (d)(i) of Class 43.1), include: The purchase and installation of heat pumps, pumps complete with controls and regulators. ...