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In effectively answering “$100,000,” CRA stated: [T]he word "consideration" must, for the purposes of subsection 148(7), receive the broad meaning generally accorded to it in the jurisprudence … [so that where] on a share redemption, the redemption price paid by a corporation is an interest in a life insurance policy that the corporation transfers to the shareholder, the CRA is of the view that the shareholder gave consideration (the redeemed shares) to the corporation for the interest thus transferred. ...

After discussing the s. 214(16)(b) designation, CRA stated: [B]y virtue of the application of paragraph 214(16)(a) and any designation under paragraph 214(16)(b), the non-resident parent could therefore file, no later than two years after the end of each calendar year in which overpayments were made to the Receiver General, a Form NR7-R to recover these amounts, unless these amounts are applied … against amounts owing to or about to become due to Her Majesty in Right of Canada. ...

In its annual return it recognizes that by virtue of s. 18(4) the interest is non-deductible and is deemed to be a dividend – and with the Treaty-reduced rate of withholding being less that the rate at which Part XIII tax actually was withheld. ...

. … At the request of the APFF, the situation described in the statement of the question and the response of the CRA will be brought to the attention of that Department [of Finance]. ...

(c)(ii)(D) – except that by virtue of s. (e)(i), the distribution would be an excluded amount if it was not derived directly or indirectly from a related business in respect of Jocelyne. ...

It follows that … the exception provided for in subsection 74.5(2) could not apply. ...

. … In response to the expressed concern where a mutual fund is invested in a significant number of countries and the burden of allocating the respective information may be burdensome to the taxpayer, the CRA will revise its administrative position and request taxpayers to provide an amended tax slip that correctly reflects the federal foreign tax credit amounts claimed. ...

. … 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. ...

. … Nevertheless, the Act will apply to avoid double taxation through the foreign tax credit mechanism. ...

A would have disposed of property for consideration equal to the decrease in the FMV of the common shares he held, pursuant to paragraph 69(1)(b),” CCRA further indicated that a price adjustment clause pursuant to the terms of the preferred shares pursuant to which their redemption value would be adjusted upwards pursuant to a board resolution to reflect the higher FMV was “not a type of price adjustment clause contemplated in … IT-169,” so that such clause would not stop such application of s. 69(1)(b). ...