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CRA found that as s. 7(1)(b) rather than s. 7(1)(a) applied to this disposition of the employee’s rights, the s. 110(1)(d.1) deduction was not available – and then went on to find that the s. 110(1)(d) deduction was not available for the same reason, stating: [S]ubparagraph 110(1)(d)(i) will not be satisfied as an employee does not “acquire the share under the agreement”, as required under subparagraph 110(1)(d)(i). ...

30 October 2016- 11:29pm CRA is negative on using a stock dividend of nominal value discretionary shares to shift value to an affiliated company Email this Content An individual) holding Class A common shares of Opco with substantial safe income on hand (“SIOH”) and an undisclosed ACB, receives a stock dividend of Class B discretionary voting shares, which are voting, participating, bear discretionary dividends and are redeemable by Opco for $1 – and then transfers the Class B share to a new Holdco under s. 85(1). ...

Summaries of 7 October 2016 APFF Financial Strategies and Instruments Roundtable, carryforward of 2013 APFF Roundtable, Q.2 under s. 54 – personal-us property and Reg. 1102(2). ...

Assuming that the yield of a preferred unit as a percentage of its liquidation (or redemption) entitlement was different than that for a common unit, it would have a different percentage entitlement to trust property than its percentage entitlement to income – so that effectively the ruling (similarly to the others) affirmed that this result was not one of the main purposes of the trust terms. ...

Summary of 29 November 2016 CTF Annual Roundtable, Q.5 under s. 207.01(1) – advantage- (b)(i). ...

Where the matter instead has not been previously considered by the GAAR Committee, the TSO will refer the matter to Headquarters prior to issuing of the proposal letter – so that it would generally only issue a proposal letter if Headquarters recommends GAAR’s application. ...

19 December 2016- 12:37am CRA indicates that draft s. 13(42)(a) operates to avoid double taxation on an arm’s length sale of a Class 14.1 property where a NAL transferor previously claimed a capital gains exemption Email this Content Where, prior to 2017, an addition to a taxpayer’s CEC was reduced based on a non-arm’s length transferor realizing a gain for which the capital gains exemption was claimed, there will be an upward adjustment under draft s. 13(42)(a) based on this amount where there is an arm’s length sale after January 1, 2017 of what now is a Class 14.1 property – so that effectively (unlike a previous version of the draft legislation) a double recognition of capital gain would appear to be avoided. ...

Summary of 22 September 2016 External T.I. 2015-0594721E5 Tr under s. 28(1)(b). ­­­­­­­­­­­­­­­­ ...

., foreign accrual property income) at a high foreign rate of tax, there will be a modest reduction in the overall rate of tax on income distributed up to him if he holds the CRA through a Canco rather than directly – and a significant deferral if funds received from the CFA by the Canco are reinvested rather than distributed to him. ...

Summary of Alison Spiers, "ECP Planning: Some Practical Considerations", Canadian Tax Focus, Vol. 6, No. 4, November 2016, p 1 under s. 248(1) – disposition. ...