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. … 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). ...

. … [W]hen a foreign trust grants funds to other organizations…the recipient organization would have to be considered “charitable” according to Canadian common law.... ...

.), also owned 100% by them, which used the land exclusively in its farming business for the first 11 of the 20 years that the land was held by the partnership – but, then, apparently ceased operations. ...

. … Thus, subsection 55(2) would not apply in the situation described above to the extent that none of the occurrences set out in subparagraphs 55(3)(a)(i) to 55(3)(a)(v) occurred as part of a transaction or event or a series of transactions or events as a part of which the dividend was received. ...

. … [I]t is a question of fact what portion of the total U.S. income tax paid by Usco1 under the Code for its taxation year ended December 31, 1997 is attributable to its share of the income of US LLC for that year. ...

After referencing the position in IT-160R3, para. 9, that a controlling shareholder generally will be considered to have received a benefit qua shareholder where “there is extensive use of the aircraft for personal purposes by the shareholder-employee or … relatives or friends,” CRA stated: [T]he benefit arising from the person's use of the aircraft by the corporation's founder-president should be based on the price of a regular first class ticket for a scheduled flight to the same destination, as the founder-president received the benefit as an employee of the corporation. ...

. … On the other hand... a meal allowance to which an employee is entitled after working a certain minimum amount of overtime to be taxable if the payment to the employee is not truly related to whether or not the employee actually takes a meal. ...