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CRA stated: [A] valid PLOI election must … include the details indicated on … Pertinent loans or indebtedness ….You may also wish to include a calculation of the change in income of each affected taxation year. ... Therefore … the CRIC would not be required to file an amended corporate tax return…. ...

CRA stated: [A] valid PLOI election must … include the details indicated on … Pertinent loans or indebtedness ….You may also wish to include a calculation of the change in income of each affected taxation year. ... Therefore … the CRIC would not be required to file an amended corporate tax return…. ...

., by deed it was agreed that the Taxpayer would have no right of accession to the garage), CRA stated: [A]ssuming that Corporation A is owner by way of superficies of the garage … then the garage, which is used by Corporation A to earn business income, would be depreciable property if the conditions set out in the definition of "depreciable property" … are satisfied. … Thus, the garage could potentially fall into Class 1(q) of Schedule II of the Regulations.... ...

. … In addition, even though we are dealing with a situation described in subparagraph 55(3)(a)(iv), it should be noted that the main purpose of that subparagraph was to prevent a form of purchase butterfly. … [I]t would seem that we are not in such a circumstance. Consequently … Holdco would have arguments in favour of concluding that the purpose test in subsection 55(2) would not be satisfied. ...

4 January 2012 External T.I. 2011-0418291E5 F- Transfert entre conjoints-- summary under Paragraph 74.2(1)(a) Summary Under Tax Topics- Income Tax Act- Section 74.2- Subsection 74.2(1)- Paragraph 74.2(1)(a) s. 74.2 attribution cease on divorce/s. 74.5(3)(b) election available after marriage breakdown Two spouses who were the equal co-owners of their principal residence and second home effected the transfer of a ½ interest in the principal residence from him to her, and of a ½ interest in the second home from her to him, shortly before their divorce. In the course of a general discussion, CRA stated: [P]aragraph 74.5(3)(b) allows spouses who are separated because of a breakdown of their marriage or common-law partnership to make an election in order to avoid the application of section 74.2. … [T]he attribution rules in section 74.2 cease to apply after the divorce. ...

. … [T]he excess portion … would not reduce the subsequently-computed CDA of the corporation that paid the dividend. Furthermore, subject to an election under subsection 184(3), paragraph 83(2)(b) results in no part of a dividend that is the subject of an election made under subsection 83(2) being included in computing the income of any shareholder. … [A]ny corporate shareholder would add to its CDA the entire dividend designated under the subsection 83(2) election (including the excess of the dividend on the capital dividend), provided that the dividend payor has not made an election pursuant to subsection 184(3). ...

. … Consequently, to the extent that you resided in Canada at any time during the 3-month period before your start date … the allowance … that you receive while posted in that country is not required to be included in computing your income for the year in which you receive it. ...

. … Where the grantor can change the terms of, or completely revoke the trust during their lifetime, they effectively retain control of the trust assets. Given this retention of control, it is our understanding that…any income generated by the trust would be reported by the grantors of the trust on a personal U.S. income tax return. … After noting that the trust might be an excluded trust, CRA stated: Where a person who has contributed property to the trust, maintains control over the trust property, (for example if the contributor is a beneficiary, which is generally the case in a U.S. revocable living trust) subsection 75(2)…. may apply. … Business income generated in the trust does not get attributed to the contributor under subsection 75(2)…. ...

The Settlement Agreement stated that the Settlement Amount was paid to them “in consideration of the loss of entitlement to PRBs, the alleged violation of their Charter rights and discontinuing litigation … as general damages for future loss of PRBs...” ... Accordingly, to [that] extent … subsection 6(3) … will deem the payment to be employment income in the year it is received. ...

However, … CRA … accepts that the portion of the dividend that may be considered safe income on hand attributable to the gain on the shares may be included in the GRIP of the corporation receiving the dividend if the corporation … designates such amount as a separate taxable dividend under paragraph 55(5)(f). ...