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., the taxation year in which the Trust's taxation year ends …. [S]ince Holdco is a beneficiary of the Trust at the time the $5,000 became payable to Holdco, the condition in paragraph 104(19)(b), that Holdco be a beneficiary of the Trust in the Trust's taxation year, is satisfied. ... If the Trust makes a s. 104(19) designation of the amount of the taxable dividend for its taxation year ending December 31, 20X1, Holdco will be required to include the dividend income in computing its income for its taxation year ending September 30, 20X2 and will be subject to s. 186(1)(b) for Part IV tax purposes – or if the Trust does not make the designation, such amount will not be a taxable dividend and Holdco will not be subject to Part IV tax on the $5,000.. ...

However, after taking into account [Reg.] 5900(3) …, since in computing the income of CFA1 and CFA2 FP is treated as if it were a separate person resident in Canada, subsection 91(5) of the Act would apply to permit a deduction by FP of the Foreign Dividends received by FP with the result that, with respect to such Foreign Dividends, there is no net income from property that would be included in the value of "A" in the definition of FAPI with respect to CFA1 and CFA2. ...

In the context of there having been an amalgamation, s. 87(2)(z.1) provided that if a capital dividend were paid by a predecessor corporation and a portion thereof would be deemed to be a taxable dividend by s. 83(2.1), the CDA of the predecessor corporation is not transferred to the amalgamated corporation – so that it would thus be necessary to determine whether all or substantially all of Corporation A's CDA, immediately before the payment of such a dividend, could reasonably be considered to consist of amounts not described in paras. ...

. … It should be noted that the totality of the interests of a partner held in a partnership constitute a single property of the partner and represent its interest in the partnership for purposes of the Act. ...

. … Similarity the fact that the Canadian company continues to collect the accounts receivable without notifying the various debtors would tend to indicate that a transfer of title has not actually taken place. ...

. … Specifically, however, repayments of a temporary nature (for example, certain cash pooling arrangements) may be evidence of a series of loans and repayments. ...

In the situation you described … the allowance based on a rate of $0.44 per kilometer received by the employee should be included in computing the employee’s income by virtue of paragraph 6(1)(b). ...

. … In Mr. A's case, it is reasonable to assume that the assumption of responsibility for the mortgage debt obligations was intended to generate income by protecting his investment. ...

. …. [N]otary fees are fees for legal services for the purposes of paragraph 62(3)(f). ...

. … However, the portion of such premiums that does not contribute to the increase of the cash surrender value of the Policy at that time will not be on hand at the safe income determination time and would therefore reduce the amount of safe income that could reasonably be considered to contribute, immediately before the Dividend-in-Kind, to the accrued capital gain on the Opco shares on which that dividend is received. ...