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CRA has now stretched s. 40(3.5)(c)(i) even further, and found that it applies if the CFA is wound-up into its three shareholders, having regard to ss. 33(2) and 3(1) of the Interpretation Act ("Words in the singular include the plural … unless a contrary intention appears. ...

Neal Armstrong, Summary of 2018 Ruling 2017-0733011R3 under s. 55(1) – distribution. ...

In policy terms, the RRSP contribution should have generated a s. 60(j) deduction – but did not. ...

Summary of 7 November 2018 External T.I. 2018-0777361E5 under s. 120.4(1) – excluded shares and s. 120.4(1.1)(b). ...

The ruling letter states: The purpose for the transfer by New FA of its FA1 Shares to BCo … occurring at the Transfer Amount as opposed to occurring at their FMV, was not to confer a benefit on a person, but rather to address certain policy concerns of the CRA by restricting BCo’s aggregate ACB of its FA1 Shares to the Transfer Amount. ...

Jorré J found that controlling the child’s Phe levels (so as to prevent severe brain damage) required that medical formula food be given in precise and timed doses, which was “no different from administering any other prescription medication,” and that “measuring and controlling Phe intake is properly characterized as administration of the therapy and not as control of X’s diet” – so that the time so spent counted towards the 14 hours. ...

This arrangement is somewhat similar to that in a 2014 ruling on an Irish contractual fund (2013-0496831R3 – see also 2015-0606141R3, 2009-0345011R3 and 2006-0199741R3), whose descriptions also looked somewhat similar to a unit trust, and was ruled upon to be a co-ownership arrangement. ...

Summary of 24 January 2019 External T.I. 2016-0651291E5 under s. 248(1) – private health services plan. ...

IV, s. 3. ­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­ ...

CRA warned that this approach was portable to resource sector reclamation obligations, but not necessarily beyond that, stating: … It is CRA’s position that reforestation obligations in the forest industry and reclamation obligations in the mining and oil and gas industries are generally embedded in the related tenures or rights, as they cannot usually be severed and would therefore depress the value. ...