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. … If this were the case…it would be reasonable to consider in this hypothetical alternative that the income earned or realized that contributed to the hypothetical capital gain on the class B shares was equal to half of the Opco safe income [thereby producing the same result as in Alternative 1]. … The dividend of $1M would normally reduce the subsequent safe income on hand. ...

After referencing the position in IT-470R, para. 27 that commissions received by such a sales employee are not taxable provided the employee owns that policy and is obligated to pay the premiums, CRA stated that this “position … does not apply if the commission amount was substantial and if the life insurance policy was acquired for investment or business purposes,” and that such IT-470R position “only applies to commissions received on the purchase of a life insurance policy, stating: Thus, in our view, the tax treatment of commissions received on the purchase of annuity contracts must be the same as that accorded to commissions received by investment dealers who acquire shares on the stock exchange or mutual funds as a personal investment. Furthermore, by giving similar treatment, the CRA takes into account the similarities that characterize these products, including the principal purpose of their acquisition, which is the expectation of a return. … Thus, in light of the facts described in Situation 1, to the extent that the commissions received are not substantial, we are of the view that Mr. ...

Income of Affiliate Year 1 Year 2 Year 3 Total Fapi income $100 $100 $100 $300 Active business Income (50) (130) 500 320 Net income (loss) 50 (30) 600 620 Loss carried forward n/a n/a (30) n/a Taxable Income $50 $nil $570 $620 Foreign tax paid or payable @ 36% $18 $nil $205 $223 CRA responded: In order for a foreign income or profits tax to qualify as foreign accrual tax it must be paid. ... In these circumstances, it is our view that the total tax of $223 should be allocated to the Fapi on a 300/620 ratio (300/620 x $223 = $108). ...

. … [S]ince the Taxpayer has an amount payable of $150,000 established on April 30, 2015, that remains unpaid, the Trustee is jointly and severally… liable with the Taxpayer, to pay the amount owing by the Taxpayer at that time. Moreover, the Trustee remains…[so] liable with the taxpayer at the time when the Minister makes a demand on the Trustee for payment (i.e., January 1, 2016) and any other time the amount owing by the Taxpayer remains unpaid while the Trustee remains the taxpayer’s legal representative. … Furthermore…the Trustee’s liability is restricted to the property in the trust…notwithstanding that between the time the taxpayer’s liability arose on April 30, 2015 and the time the Trustee liquidated the Portfolio in satisfaction of the demand to pay on January 7, 2016, the value of such property declined in value from $100,000 to $70,000. ...

. … [T]he payment, deemed by virtue of subsection 80.01(3) to be made, immediately before the time immediately before the amalgamation, by Aco to Bco… (i.e., CDN$1,000,000) would be equal to the ACB to Bco of the Debt (i.e., CDN$1,000,000). … [U]nder subsection 80.01(3), the Debt would be deemed to have been settled immediately before the Calculation Time. ...

The question of whether you have a self-contained domestic establishment elsewhere that is a principal place of residence … can be answered by examining the following factors, which are not exhaustive: What was your family's place of residence while you were working on the special work site? ... … Thus, the allowance you receive for board and lodging may be excluded from computing your income only if your work at the special work site is of a temporary nature, if your Property A is a self-contained domestic establishment considered as your principal place of residence and if all other conditions for the application of subparagraph 6(6)(a)(i) are satisfied. ...

. … The presumption in subsection 12(9) with respect to deemed interest is applicable for the purposes of subsection 12(4). … The T5 Guide …states that the interest to be included in Box 13 is interest that has not previously been reported. ...

. … [I]f all the[se] conditions … are satisfied, considering the reasonableness of the allowances paid to Responsible Employees, we are of the view that such allowances could be excluded in computing their income by virtue of subparagraph 6(6)(b)(i). ...

., before the individual became owner of the home – it did not yet exist) be eligible for the home renovation tax credit ("HRTC")? In responding affirmatively, CRA stated: In the situation where an individual constructs the individual’s housing unit on land owned by the individual, it is generally the CRA's view that the individual will be considered to own a housing unit for HRTC purposes as soon as the housing unit is habitable. … In other words, the housing unit will be an eligible dwelling (as defined in subsection 118.04(1)) if it became habitable at the time of the renovation or alteration and is ordinarily inhabited by the individual, by the individual’s spouse or common-law partner or former spouse or common-law partner or by a child of the individual during the period that begins on January 28, 2009 and that ends on January 31, 2010. ...

. … Whether an amount paid or payable by the transferor to the transferee constitutes a “reinsurance premium” depends on the legal manner by which the insurance business is transferred and whether it is done under a reinsurance arrangement. ... [Respecting whether] the term “reinsurance commission” … carries the meaning [in Reg.] 1408(1)…[w]e note that there is no explicit reference in the definition to subsection 138(11.5) or (11.94) of the Act. ...