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Situation 4 (i) Opco was incorporated with all of its shares hating been issued to one trust as follows: Shareholder No. and Class of Shares Subscription Price Trust 200,000 Class A preferred 200,000 Trust 1,000 common $ 1,000 The Class A preferred shares are redeemable and retractable for $l each and bear a 7% non-cumulative dividend. ...

However, based on two previous decisions, (Thompson Constr'n & Vancouver Tug Boat) he felt constrained as a matter of consistency to treat boiler costs as capital. ...

Si l'on utilise la méthode du coût moyen pour déterminer le coût des actions, le PBR de chaque action pour le bénéficiaire serait de 167 667 $. ...

In this case, Partner A's ACB of its partnership interest at the time of admission of Partner 8 would be $10 million for purposes of allocating income, losses or C0GPE, as the case may be, not $ nil as suggested in the hypothetical situation. ...

Yours truly, XXXXXXXXXX Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch ...

Effect of Paragraph 1(2)(c) of EIA for Income Tax Purposes Paragraph 1(2)(c) of the EIA provides as follows: (2) For the purposes of this Act [...] ...

(page 15 of Text, Commentary and Cases on Trusts (fourth edition) by Oosterhoff & Gillese (student edition)) ii) The three certainties To create a trust, there must be certainty of intention to create the trust, the subject matter must be described with such certainty that it is ascertained or capable of ascertainment, and those who are to benefit from the trust- that is, the objects or beneficiaries- must also be described in terms clear enough that the trust obligation can be performed properly. ...

As a result of the redemption by TransfereeCo of its TransfereeCo Preferred Shares as described in paragraph 14 above and the consequential purchase for cancellation of the Class XXXXXXXXXX common share of XXXXXXXXXX as described in paragraph 15 above: (a) By virtue of paragraphs 84(3)(a) and 84(3)(b) of the Act: ••• TransfereeCo will be deemed to have paid, and XXXXXXXXXX will be deemed to have received, a taxable dividend equal to the amount by which the amount paid in respect of the redemption of the TransfereeCo Preferred Shares exceeds the PUC thereof; and (ii) XXXXXXXXXX will be deemed to have paid, and TransfereeCo will be deemed to have received, a taxable dividend equal to the amount by which the amount paid in respect of the purchase for cancellation of the common share of XXXXXXXXXX exceeds the PUC thereof; (b) Provided that neither of XXXXXXXXXX nor TransfereeCo is entitled to a dividend refund in respect of its taxation year in which it is deemed to pay the dividend referred to in (a)(i) or (ii) herein, neither of XXXXXXXXXX nor TransfereeCo will be subject to Part IV tax under subsection 186(1) of the Act in respect of such dividend; and (c) The taxable dividends deemed to have been received by XXXXXXXXXX and TransfereeCo as a result of the redemption and purchase for cancellation referred to in paragraph (a) herein will be deductible by each of them in computing its respective taxable income pursuant to subsection 112(1) of the Act. ...

7 February 1991 Income Tax Severed Letter- Review of the General Anti-avoidance Rule Course Material- Lesson #3 Unedited CRA Tags 245(2) Subject: Review of The General Anti-Avoidance Rule Course Material- Lesson # 3 We have now had a chance to complete a technical review of the course material titled “The General Anti-Avoidance Rule”. ...

QUESTIONS 42 & 46 MANAGEMENT FEES AND BONUSES The Department has a long standing practice not to challenge the reasonableness of salaries or bonuses paid to a principal shareholder who is active in the corporation's business and the corporation has either established a practice of distributing profits to such employee\shareholder in this manner or a policy of declaring bonuses to shareholders to remunerate them for the profits the corporation has earned that in fact are attributable to special know-how or skills of the shareholder. ...