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28 September 2018 External T.I. 2018-0779261E5- Investment management fees-- summary under Subparagraph (b)(i) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (b)- Subparagraph (b)(i) proposal to impose advantage tax, where RRSP or TFSA fees are paid by the annuitant or holder, pending a Finance review In 29 November 2016 CTF Roundtable Q. 5, 2016-0670801C6, CRA indicated that it now considered the payment of fees for investment management of an RRSP, RRIF or TFSA by the plan annuitant or holder typically will be considered to be an “advantage” giving rise to tax under s. 207.05(1) equal to 100% of the fee amount (noting inter alia under the hypothetical arm’s length test in s. 207.01(1) – advantage- (b)(i) that it would not be “commercially reasonable for an arm’s length party to gratuitously pay the expenses of another party”) but that to give the investment industry time to make the required system changes, it would defer applying this new position until January 1, 2018. 2017-0722391E5 announced a one-year extension to January 1, 2019. ...

. … As such, in the example provided, ACo would be first subject to the passive income reduction in its first taxation year beginning after 2018 (i.e., ACo’s taxation year ending December 31, 2019). ...

. … In the particular situation, Partnership had a taxation year that commenced on January 1, X9 and ended immediately before the time immediately prior to the time it ceased to exist. ...

. … [I]t is our view that the requirements of paragraph 108(2)(a) have been satisfied. ...

18 June 1998 External T.I. 9805705- ASSOCIATED CORPORATIONS-- summary under Subsection 256(1.4) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1.4) In indicating that s. 256(1.4)(b) could apply where pursuant to a unanimous shareholders agreement a corporation would automatically acquire the shares of a shareholder where there is a change in control of the shareholder, a receiver of the shareholder was appointed, the shareholder breached specified covenants in the agreement, the shareholder encumbered its shares or they were attached, Revenue Canada stated "... ...

[stated]: "...., the Department is prepared to make an exception in cases where a corporation does not exercise significant influence, if it can be clearly demonstrated (emphasis added) that the income of the other corporation contributed to the unrealized gain on the shares. ...

Thus, in our view, term deposits and guaranteed investment certificates issued by XXXXXXXXXX to non-residents would constitute similar obligations for the purposes of subclause 212(1)(b)(ii)(C)(II) …. ...

The correspondent: noted that the "acquisition" or "sale of stock index futures is similar in nature to a transaction in "naked options" in that no property is actually purchased or sold and, further, that paragraph 25 of … IT-479R states that, while transactions in "naked options" are normally on income account, the Department will accept the reporting of gains or losses on capital account provided this practice is followed consistently from year to year. ...

Carried on"): Respecting the exclusion in Article XIII, paragraph 4 of the Canada-Netherlands Convention for property (other than rental property) in which the business of the company is carried on, RC stated that in its view "Oil & Gas reserves and royalty interests will be excluded from the definition of immovable property... if the owner is actively engaged in the exploitation of natural resources and if such assets are actively exploited or kept for future exploitation by such owner.... ...

. … [B]y virtue of point (4) above, the settlor would not retain all incidents of beneficial ownership. ...