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CRA indicated that any income or loss from the portfolio X investments, or property substituted therefor, would be deemed to be the income or loss of Spouse A, and any taxable capital gain or allowable capital loss from the disposition of such investments or property substituted therefor will be deemed to be the taxable capital gain or allowable capital loss of Spouse A – for so long as such property continues to be held by the trust, and while Spouse A is resident. ...

. … [U]nless the Dependent Beneficiary is the person legally entitled to the surplus income a trust will not qualify as an LBT as there is the possibility that a person other than the Dependent Beneficiary can receive or obtain, during the Dependent Beneficiary’s lifetime, the use of the income of the trust. ...

However, practical solutions to these types of technical issues exist and therefore the CRA does not consider that a flexible approach is necessary in the[se] circumstances …. ...

Thus, it is our view that the amount will not be included in the borrower’s income …. ...

X did not wish his four children- who along with his wife and a family company were the beneficiaries of an inter vivos trust (“Trust 1”) holding shares of family companies – to be distributed the assets of Trust 1 (such shares) immediately before the 21 st anniversary of the settling of Trust 1. ...

(a), the joint designation referred to therein was required to “be made jointly by the deceased annuitant's legal representative and the Spouse” so that “in order for the designation to be valid, the Spouse must be alive at the time the joint designation is made,” and so that a “joint designation made … [with] the deceased Spouse's legal representative would not satisfy this requirement.” ...

CRA indicated that it had the discretion to grant a request to reduce the carrybacks so as to eliminate the GRIP reduction and associated Part III.1 tax (so that it might grant such request if it was satisfied that this was “a situation involving a bona fide error and not amounting to retroactive tax planning) provided that the loss years (2019 or 2020) were not statute-barred and that the request to reduce the carryback satisfied “the conditions … in subparagraphs 152(4)(b)(i) and 152(4.01)(b)(i) in respect of the [prior] Years.” ...

. … Given the fact that a non-resident that receives a letter containing proposed assessed amounts would almost certainly make a valid paragraph 94(3)(f) election before an audit assessment is actually issued, it appears unlikely that such a non-resident would ever be prevented from making a valid election. ...

13 April 2023 External T.I. 2017-0684341E5 F- Perte au titre d’un placement d’entreprise-- summary under Paragraph 39(1)(c) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(c) active business for SBC purposes can continue after regular business operations have ceased/ sale of debt for $1 to unrelated purchasers might be a non-arm’s length transaction An individual was the sole shareholder, and held an interest-bearing debt (the "Debt" – acquired for an income-producing purpose), of a corporation operating a restaurant which in 20X1 sued the franchisor at the same time as closing the restaurant. ...

It could, however, assess the resident beneficiary for an amount not exceeding $100,000 on December 31, 2022 given that the conditions in s. 94(7) were by assumption satisfied for the 2020 year – and this was so even if s. 94(3) had ceased to apply to the trust for its 2021 or 2022 taxation year. ...