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Furthermore, we are of the view that the French and English versions of paragraphs 256(3)(a) and 256(6)(a) have the same meaning and that the expression "under which" used in the English version does not allow for a broader interpretation of the verb "stipuler" used in the French version …. ...

" In indicating that an investment allowance might not be allowed for such a policy, CRA stated: [T]he only assets issued by a corporation that is a financial institution that qualify for the investment allowance … are a share of the financial institution or a long-term debt. ...

. … [T]he fees paid by the corporation for the principal shareholder should be included in the principal shareholder's income pursuant to subsection 15(1). ...

Second, a corporation that receives an eligible dividend from a payer corporation is subject to Part IV tax whether or not the payer corporation receives the DR – so that if CCRA allowed a corporation to waive a DR, this would have no effect on the Part IV tax payable by the other corporation. ...

A, who had held all the shares of HoldcoA on April 26, 1995 at which time HoldcoA held a policy on the life of A whose purpose was to fund the redemption of such shares, transferred those shares to another wholly-owned corporation (HoldcoB – all of whose shares being Class B shares were held by him) under s. 85(1) in consideration for 100 "new Class B shares" of HoldcoB. ...

In this regard, the Directorate stated: [T]he provisions of paragraph 40(2)(g)(ii), that deem a loss on the disposition of certain debt obligations to be nil, do not apply since the … debt obligation was interest-bearing, as the taxpayer was subrogated by the financial institution as to the interest-bearing mortgage ...

. … [T]he provisions of section 22 of the Regulation will not, in and of themselves, prevent the deduction of interest on money borrowed to acquire common shares of a QBIC if there is otherwise a reasonable expectation, at the time the shares are acquired, that the holder of the common shares will receive dividends. ...

. … [T]he direct use of the borrowed money is for personal purposes, which is not an eligible use. ...

CRA responded: Under a "charitable" annuity arrangement … a donor transfers an amount to a trust in consideration for which the donor acquires a right to receive an annuity from the trust. ...

In those circumstances, we doubt that the work of the employees is of a temporary nature and, in our view, the … premium could not be excluded from the employees' income by virtue of subsection 6(6). ...