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B … would be deemed to be nil by virtue of paragraph 40(3.6)(a). Consequently, no amount of the Denied Loss could be attributed to Ms. A under subsection 74.2(1) …. By virtue of paragraph 40(3.6)(b), the amount of the Denied Loss … could, however, be added to … the ACB, to Mr. B, of each of the common shares of … Opco that is owned by him immediately following the disposition of such preferred shares of the capital stock of Opco. ...

Was the requirement in s. 110.6(1) – qualified small business corporation share – para. ... CRA responded: In this case, the "determination time" … is February 5, 2011. ... X … owned the shares … the requirement regarding the 24-month holding period of the shares would not be satisfied …. ...

CRA responded: [T]he conditions in the preamble to subsection 249.1(4) must … be … satisfied in each of the fiscal periods following that first fiscal period of the business in order for subsection 249.1(4) to continue to apply …. Among the conditions … [is that] each member of the partnership is an individual and the partnership is not a member of another partnership. … [W]hen Partnership A became a member of Partnership B, the two partnerships no longer satisfied the conditions of subsection 249.1(4) for the current fiscal period …. ...

CCRA stated: [T]he conversion or exchange rights attached to the newly acquired Class A shares … and permitting the exchange of such shares for Class B shares … would technically constitute a "right to acquire" the substituted property …. These conversion or exchange rights would therefore be deemed to be property identical to the Class B shares … previously disposed of by the Taxpayer. Consequently, the loss incurred by the Taxpayer and resulting from the disposition of the Class B shares … would be a "superficial loss" …. ...

Canadian Acme Screw & Gear, Ltd. [1971] S.C.R. 628. ...

19 October 2005 Internal T.I. 2005-0151211I7- Financing expenses-- summary under Paragraph 20(1)(e.1) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e.1) indirect use test inapplicable to s. 20(1)(e) or (e.1), and “relate solely to … year” test not satisfied by lump sum issue fee reimbursement to parent A Co, a public company, issued interest-bearing debentures to arm's length parties, and on-lent the borrowed money to its "great-grandchild" subsidiary (D Co) at the same interest rate. ...

Deloitte & Touche Inc., [2007] 2 C.T.C. 253, 30 C.B.R. (5th) 81, (Sask. ...

After providing a general summary of the rules respecting personal services businesses, CRA stated: Revenu Québec has produced a document entitled Status of a worker – Self-employed workers in the Information Technology Sector, which reported on the work of the Committee [formed in June 2011 and consisting of representatives from Revenu Québec, the Canadian Federation of Independent Business and The Quebec Association of IT Freelancers]. ...

See detailed summary under s. 132.2 – qualifying exchange. ...

In this context, the use of the terms "action de remplacement " and "share for which the affiliate share was substituted" in the French and English versions of paragraph 93(2.01)(a) refer to the concept governed by paragraph 248(5) in respect of property that is shares. ...