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In finding that such exchange likely would be viewed as one between persons not dealing at arm’s length so that s. 84.1 likely would limit the PUC of the shares received on the above exchange, CCRA stated: [T]he parties … could be acting together in a highly interdependent manner with no separate interest, particularly in relation to the share transfer described [above]. Furthermore, it seems … that Opco would have no distinct interest in acquiring shares of Holdco I, Holdco II and Holdco III, other than to accommodate its ultimate shareholders, namely Mr. ...

In finding that such exchange likely would be viewed as one between persons not dealing at arm’s length so that s. 84.1 likely would limit the PUC of the shares received on the above exchange, CCRA stated: [T]he parties … could be acting together in a highly interdependent manner with no separate interest … [and] Opco would have no distinct interest in acquiring shares of Holdco I, Holdco II and Holdco III, other than to accommodate its ultimate shareholders, namely Mr. ...

. … Furthermore … the reason the employer rents an assembly area and provides transportation is to reduce the cost of maintaining the gravel road and the cost of damages it would incur if the employees' or independent contractors' cars were damaged due to the condition of the road. ...

. … [A] callable step-up bond is no different than any other step-up bond that has increasing interest rates throughout its term to maturity…. ... Callable step-up bonds are treated as having a maturity…that is, the maturity date that is listed as its term. … [T]he excess interest income reported for tax purposes can be deducted under subsection 20(21)... ...

X, as the usufructuary, was to be treated as the life beneficiary of the resulting deemed trust that arose under s. 248(3), it addressed the s. 105(1) benefit issue arising from his rent-free use of the residence, stating: [A]lthough [CCRA] … considers the use of trust property by a beneficiary of the trust to be a benefit pursuant to subsection 105(1), no assessment is generally made in respect of a benefit arising from the use of personal-use property owned by the trust …. ...

. … [Such] refund … is an amount covered by paragraph 12(1)(x), but that paragraph will not apply if the refund amount has already been included in the taxpayer's income or has already reduced the expense in accordance with accepted commercial principles. ...

. … [Such] refund … is an amount covered by paragraph 12(1)(x), but that paragraph will not apply if the refund amount has already been included in the taxpayer's income or has already reduced the expense in accordance with accepted commercial principles. ...

CCRA responded: [W]here a note is part of the consideration issued … subparagraph 110.6(14)(f)(i) could apply because of the wording of the Act. Indeed … the shares are issued as consideration for other shares even if a note is issued as part of the same transfer. ...

It is, however, a real and enforceable debt and therefore a true obligation within the meaning of the above-mentioned Interpretation Bulletins and decisions (for an example of such an obligation in the context of a foreign exchange loss, see … Canadian General Electric …. ...

. … [S]ubsection 249.1(2) would not apply to this type of transaction. The professional corporation has … received on the transfer of the partners' interests in the SENC the right to the income attached thereto such that the professional corporation is not in a position where no share of the income or loss of the SENC would accrue to it. ...