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. … If that were the case, the vacant land held by [the first] corporation would not be assets used principally in an active business carried on primarily in Canada by the corporation for the purposes of the definition …. ...

15 October 2004 External T.I. 2004-0068421E5 F- Bien de remplacement-- summary under Subsection 44(5) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(5) replacement property can be acquired from a related person The taxpayer and his brother acquired, in equal shares, a rental property ("Immovable A") that was rented to residential – as well as commercial tenants being the respective brothers’ holding companies. ... CRA indicated that “there is nothing in the wording of subsections 44(5) and 13(4.1) that would lead to the conclusion that the acquisition of a replacement property from a related person or from a corporation in which the taxpayer holds shares is prohibited for the purposes of these provisions” – although it indicated that whether s. 69 or 15 applied would need to be considered. ...

Y holds ½ of the shares (being common shares) of Zco. A shareholders' agreement provides that one shareholder (Mr. ... Therefore … Aco and Zco would be associated with each other pursuant to paragraph 256(1)(b). ...

In addition … it may be possible … to apply subsection 18(12) to a business loss allocated to a partner by the partnership. ...

17 February 2005 External T.I. 2004-0091811E5 F- Exemption pour résidence principale-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence- Paragraph (a) where residence held by son and mother in equal co-ownership is 2 units each occupied separately, each could technically access the exemption for only a ¼ interest A single taxpayer (Mr. ... However, in such a situation “the relevant Tax Services Office [should] determine … what would be the appropriate result in accordance with the tax policy underlying this exemption.” ...

22 May 2001 External T.I. 2000-0021095 F- DEMUTULISATION NON-RESIDENT-- summary under Subsection 139.1(16) Summary Under Tax Topics- Income Tax Act- Section 139.1- Subsection 139.1(16) non-resident interest person needs to make the election for s. 139.1(16) to apply – if so, per s. 139.1(16)(k), no Part XIII tax applicable to individual re the cash payment Regarding the application of s. 139.1 to a non-resident corporation, not carrying on business in Canada, which is the policyholder of a group life insurance policy for the employees of its Canadian subsidiary, CCRA reviewed s. 139.1(16) and stated: [A] non-resident corporation that does not carry on any business in Canada is generally not a person whose taxable income is exempt from tax under Part I …. ...

29 May 2001 External T.I. 2001-0075245 F- SOCIETE DE GESTION DE PENSION-- summary under Subparagraph 149(1)(o.2)(i) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(i) s. 149(1)(o.2)(i) corporation can be incorporated for the administration of more than one RPP – but cannot be incorporated to provide management services to other RPPs Regarding the application of s. 149(1)(o.2)(i) to a corporation incorporated before November 17, 1978 specifically for two registered pension plans but now wishing to offer management services to several other registered pension plans, CCRA indicated: [T]he expression “in connection with, or for the administration of, a registered pension plan” must be interpreted by applying subsection 33(2) of the Interpretation Act, which states that "[w]ords in the singular include the plural, and words in the plural include the singular” … [so that] a pension corporation that was formed before November 17, 1978 in relation to one or more registered pension plans satisfied the condition set out in subparagraph 149(1)(o.2)(i). ...

CCRA stated: [T]he cost to the acquiring corporation of each share acquired would generally correspond to the total of the amount paid in cash and the amount added by the acquiring corporation to its stated capital account …. Consequently … the cost would be $10 per share acquired by Pubco. ...

However … an employee may withdraw from the plan in special circumstances such as financial or other difficulties, which must be stipulated in the plan and be subject to the employer's discretion. Lay-off or dismissal of the employee would also be part of those special circumstances. … If the employee decides to retire at the end of the leave and does not return to work as originally agreed, the deferred amounts will be taxed in the year in which it is known that the above condition will not be satisfied. ...

23 August 2001 External T.I. 2001-0086235 F- CONVENTIONS FISCALES A.18-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 QPP and OAS were pension payments made under social security legislation for purposes of the Slovenia and Croatia treaties Regarding the tax treatment of QPP and OAS payments made to residents of Slovenia, Croatia and Germany, CCRA indicated that: Under the Slovenia Convention, since “pension” was not defined, its meaning under s. 5 – pension – (a)(ix), of the ICTCIA applied to render them pension payments. ...