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. … [T]his approach should be preferred, in any situation similar to that described in Scenario 3, for establishing who has de jure control of a corporation. ...

. … After paraphrasing the definitions of "resident contributor," "contributor" and "resident beneficiary" (which latter definition referenced a "connected contributor to the trust,") CRA stated: Under subsection 94(1), a "connected contributor" includes any contributor to the trust at a particular time other than a person all of whose contributions to the trust made at or before the particular time were made at a non-resident time of the person as defined in subsection 94(1). ...

. … Mr. B's income will not be considered in setting the CCTB for the months before July 2012 since paragraph 122.62(7) (b) applies only to a month that begins after a change in marital status. ...

This combined value should be included in Category 6 of Form T1135, " Other property outside of Canada. ...

X would also, by virtue of subparagraph 251.1(4)(d)(i), be a majority interest beneficiary of Trust B… … Trust A and Trust B would thus be affiliated…by virtue of subparagraph 251.1(1)(h)(i)…. ...

CRA responded: [T]he elements applied to determine the proceeds of disposition of the building according to the calculation rules set out in paragraph 13(21.1)(a) … are, inter alia, the fair market value of the land immediately before its disposition and its cost amount to the vendor. ...

. … If instead of selling the shares to you and your wife, the Shareholder had sold the shares of the Corporation to Holdco and received a note, subsection 84.1(1)(b) of the Act might apply to deem the Shareholder to have received a dividend on the disposition of the shares. ...

. … The Corporation appears to be the particular qualifying person which has agreed to issue or sell the shares. ...

Internal Revenue Code (footnote 1 [Section 691(c)(1) provides that a person who includes an amount of income in respect of a decedent (“IRD”) in gross income under § 691(a) is allowed as a deduction, for the same taxable year, a portion of the estate tax paid by reason of the inclusion of that IRD in the decedent’s gross estate]), such excluded amount would not be taxable in Canada and may be deducted by the Canadian resident taxpayer in computing his taxable income in accordance with subparagraph 110(1)(f)(i). ...

. … [T]he CRA accepts that the shares being the subject to the potential operation of a [separate] PAC will not, in and of itself, negate the amount that was specified for the purposes of subsection 191(4). ...