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After indicating that, assuming that s. 55(4) did not apply, the s. 55(3)(a) exception applied, CRA noted: [T]his Directorate has previously taken the position that subsection 55(4) does not apply where it is shown that a parent retained de jure control of a corporation newly-formed by one of the parent’s children primarily for the purpose of protecting the parent's economic interest in the newly-formed corporation, and that none of the primary purposes of the transactions were to cause persons to become related to each other …. ...

If, according to the T4A (P) slip issued by the RRQ, the death benefit was paid to the "heirs …” of the deceased, this amount must be included in the income of the estate in light of subsections 104(1) and 248(1), under which the heirs of a deceased taxpayer are deemed to be the estate of the deceased for the purposes of the Act. ...

. … [I]t is unlikely that the clients' places of business would constitute a regular place of work of the representative. ...

. … [I]n a situation where the Partnership employs more than 5 full-time employees in its business, the corporation is considered to employ more than 5 full-time employees in that business and thus the corporation meets the exception described in paragraph (a) of the definition of SIB. ...

. … [I]n a situation where the Partnership employs more than 5 full-time employees in its business, the corporation is considered to employ more than 5 full-time employees in that business and thus the corporation meets the exception described in paragraph (a) of the definition of SIB. ...

In the course of making general comments after having indicated that there were insufficient facts, CRA stated: A could be not dealing at arm's length with UNRELATEDCO with respect to A's disposition of the shares of OPCO …. ...

After referring to s. 37(13), CRA stated: [A]dministrative support tasks in respect of the activities of a subsidiary of a taxpayer would not be considered to be SR&ED of the taxpayer because the condition in paragraph 37(13)(b) is not satisfied since the administrative support tasks would not be SR&ED of the subsidiary …. ...

In rejecting this proposition, CRA stated that “it is clear that the preferred shares … were not held by the particular individual on April 26, 1995, notwithstanding that the preferred shares would be deemed to be substituted property for the common shares,” and also noted that a stock dividend did not come within the continuity provisions of s. 131(12) of the amending Bill. ...

. … [O]ne item that generally reduces the adjusted cost basis [of the policy] is the "net cost of pure insurance", as defined in subsection 308(1) of the Income Tax Regulations, calculated immediately before the end of the calendar year ending in a taxation year commencing after May 31, 1985, in respect of an interest in a life insurance policy (other than an annuity contract) last acquired after December 1, 1982. ...

. … [S]ubparagraph 88(1)(c.3)(ii) would not apply in such a situation. ...