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If the corporation declines in value and he does a “refreeze” so that he now holds preferred shares with a redemption value of $3 million, the outstanding amount will remain at $15 million – or only be reduced to $12 million if those preferred shares are redeemed in full for cash. ...

Summaries of 2016-0679281R3 under s. 86(1) and s. 248(1) – disposition. ...

Summary of 26 July 2018 Internal T.I. 2018-0768281I7 under s. 94(1) – non-resident time. ...

Neal Armstrong Summary of 8 March 2018 CBA Commodity Taxes Roundtable, Q.7 under ETA s. 123(1) – money. ...

., the reputation of the hedge fund managers – and these offshore funds were selected as being the best choices. ...

Respecting an assertion by the correspondent that s. 98(5) applied to the partnership winding-up, CRA indicated that this raised the issue of when the partners transferred their interests in the partnership to Opco, and stated: [W]here such transfers occur simultaneously … subsection 98(5) would not be applicable, given that Opco would not be a partner of Partnership immediately before Partnership ceased to exist. ...

CRA went on to indicate that this was not especially harsh: [E]ven though computing a corporation’s Part IV tax and dividend refund by successive circular calculations inflate these amounts and … these calculations are tedious, they are not financially injurious to the connected corporations as the net amount of Part IV tax payable by one corporation (Part IV tax payable minus its dividend refund) will equal the net amount of the dividend refund (dividend refund minus Part IV tax payable) of the other. ...

VI, s. 1 – municipal transit service. ...

On a going-forward basis the CRA is willing to provide assurance on the tax treatment of the discretionary dividend shares, but only in the context of a ruling request – and thus will no longer express its views on this matter in Technical Interpretations or Roundtable responses. ...

Summaries of 20 August 2018 External T.I. 2018-0739761E5 under s. 146.2(2)(c) and s. 207.01(1) – advantage, and summary of 20 August 2018 External T.I. 2017-0731541E5 under s. 146.2(2)(c). ...