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However, if the interest at 5% was not a “reasonable return,” the split income amount would not be the total interest amount but, rather, only the excess over the reasonable return – so that, for example, if the reasonable return was 3%, the split income inclusion would be 2%. ...

CRA noted that no dividend refund arises to Opco on the $1,000,000 eligible dividend, so that there is no Part IV tax payable by Holdco thereon under s. 186(1)(b) – and that such dividend also is not subject to s. 55(2) as it does not exceed the $1,000,000 of safe income. ...

X’s will – which provided the same terms as described above. Here, since the shares held in the trust were not acquired by it as a consequence of Mr. ...

Consequently … it is possible that the conditions of subsection 104(18) could be satisfied in respect of the child or children of the deceased who are beneficiaries of the estate and who have not attained 21 years of age at the end of a particular taxation year. ...

Accordingly, the amendments “apply only to dispositions that occur on or after … June 29, 2021.” ...

It would make no difference if the house was co-owned by the two spouses (or if they were common-law partners) – rather than owned only by Mr. ...

The application of subsection 245(2) could be considered if the Pipeline Planning is structured to avoid the application of section 84.1 …. ...

. … What constitutes appropriate documentation depends on the specific facts and circumstances, but may include: non-consolidated financial statements of the foreign affiliate, trial balance of the foreign affiliate, complete minute books of the foreign affiliate, income tax returns and all relevant supporting schedules for the income tax returns of the foreign affiliate, support for income tax paid by the foreign affiliate, and relevant supporting documentation: describing the business(es) of the foreign affiliate, related to the nature of the income earned by the foreign affiliate, related to transactions involving the foreign affiliate, and related to dividends paid or received by the foreign affiliate. ...

It was “Rulings’ view that allowing subsection 220(2.1) to waive a taxpayer’s requirement to file an election not listed in Regulation 600 would negate the specific intention of Parliament in limiting late elections to only those that are prescribed in [Reg.] 600” – and, in any event, the CIF provision was not a provision of the Act itself, as required by s. 220(2.1). ...

It was “Rulings’ view that allowing subsection 220(2.1) to waive a taxpayer’s requirement to file an election not listed in Regulation 600 would negate the specific intention of Parliament in limiting late elections to only those that are prescribed in [Reg.] 600” – and, in any event, the CIF provision was not a provision of the Act itself, as required by s. 220(2.1). ...