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. … [and] that a legal obligation to pay under contract does not exist until all contractual preconditions to which the payment relates are fulfilled [citing Wawang Forest Products]. ...

After noting that the definition of qualified carbon capture expenditure – A(b)(i) in s. 127.44(1) refers to “the amount of energy expected to be produced for use in a qualified CCUS project over the project's total CCUS project review period”, CRA stated: [I]t is our view that there is no restriction on counting energy delivered through an electrical utility grid in determining “the amount of energy expected to be produced for use in a qualified CCUS project”. ...

. … Therefore…paragraph 248(28)(a)… applies to remedy the situation and avoid double taxation of the same amount. ...

Would Opco and Newco be associated under ss. 256(1.2)(f)(ii) and 256(1.3) – and would it make any difference if the trust deed precluded only the distribution of income before 18? ...

. … If corporate income has not previously been taxed, whether because the corporation was entitled to certain tax benefits under the Act or for any other reason, then a dividend paid by the corporation from such income should be subject to subsection 55(2) unless none of the purposes of the dividend is described in proposed paragraph 55(2.1)(b). ...

X of the preferred shares would be attributable to the capital gains deduction – so that there would be a deemed dividend of $500,000 paid by Cco to Mr. ...

X, CRA indicated that Amalco shares that were substituted for his Holdco common shares had not been held by anyone other than him, and that, prior to being replaced by Holdco shares, the original Opco share had not been owned by anyone other than him – and in this regard, stated that s. “110.6(1)(e) can apply respecting multiple substitutions.” ...

(a)(ii) of that definition, that “ prima facie, the mere fact of M-1 and C-1 acting as directors of Investco would not be sufficient in itself to consider that they were actively involved, on a regular basis, in the activities of Investco's business,” but that the “ownership test” in s. ...

On 20 June 2013 FA2 made the $1,500 "FA2 Loan" to Canco for 10 years – but FA2 was wound-up into FA1 on 20 February 2014. ...

. … With a dividend in the order of magnitude of $35,000…we could conclude that the reduction is significant or the increase in cost is significant. ...