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. … CRA considers that "principal" refers to the person's chief or main business activity. ...

. … CanOpco's legal obligation to pay interest expired on the day it obtained protection from its creditors under the CCAA. ...

. … The failure to file the Form T1135 return on time results in the assessment of penalties under subsection 162(7), which is in Part I of the Act. ...

The correspondent considered that the retained earnings of ULC should exclude its proportionate share of the Partnership income for the stub period on the basis that " 2007-0248961R3 indicate[s]... that section 96 informs the determination of the amount of partnership income to be included in determining the amount of a corporate partner's retained earnings for the purpose of the thin capitalization rules. ...

…[T]he features described … in [the documentation], in and of themselves, would not cause the interest on the borrowed money to not be deductible.... ...

(at para 42)) rather than their cost – although, here, the denied operating expenses and CCA of the corporate owner "can be used to establish the value of the benefit conferred on Mr. ...

A's father, CRA indicated that there would be no taxable benefit respecting such use by the father for the years under review before the effective date of s. 15(1.4)(c) – but thereafter, the value of the benefit enjoyed by the father was taxable to the son (Mr. ...

Canco paid Japanese income tax on the capital gain reported on such disposition and also reported a capital gain for Canadian tax purposes – but later determined (with CRA's concurrence) that the fair market value of the shares had been nil. ...

. …. If, in the case described, there in fact is an allocation of capital gains of the SEC to its partners, we believe it would be difficult to maintain that they do not retain their character in the hands of the latter, including the Limited Partner. ...

. … Canco was deemed to realize a gain in Year 3… equal [to] the total of amounts deducted by Canco under paragraph 113(1)(d) in respect of Forco dividends received through LP that were paid out of Forco's pre-acquisition surplus, less any foreign tax paid in respect of Canco's share of those dividends. ...