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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). ...

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 …. ...