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Subco used $2,000 borrowed from a third party to acquire assets with a cost amount of $3,000 – which subsequently lost all their value. ... Parentco would essentially have taken two deductions for the same loss of $1000 – first the $1000 loss on the Subco shares under 50(1), and an additional loss of $1000 on the assets of Subco. ...

. … Consequently, the dividend received by Ms. Y could qualify as an excluded amount pursuant to subparagraph (e)(i) …. ...

3 December 2024 CTF Roundtable Q. 3, 2024-1038151C6- Notifiable Transactions-- summary under Paragraph 237.4(4)(b) Summary Under Tax Topics- Income Tax Act- Section 237.4- Subsection 237.4(4)- Paragraph 237.4(4)(b) B2B reporting engaged where loan from immediate NR parent (funded in turn in part with debt from ultimate parent) bears reduced (10%) withholding References in NT 2023-05 to a designated transaction include: [S]ubsections 212(3.1) to (3.3) help to ensure that withholding tax under Part XIII is not circumvented through the use of back-to-back lending arrangements …. There are also character substitution rules in the Part XIII context. … A non-resident person (NR1) enters into an arrangement to indirectly provide financing to a taxpayer through another non-resident person (NR2). ...

. … [A]s a practical matter…[w]here the distribution is a dividend or a return of legal capital under the foreign corporate law, that characterization will generally not be challenged by the CRA. ...

7 October 2011 Roundtable, 2011-0411951C6 F- Retenues à la source- options d'achat d'actions-- summary under Paragraph 6204(1)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 6204- Subsection 6204(1)- Paragraph 6204(1)(b) loss of prescribed share status where employer granted redemption right to cover s. 153(1.01) withholding obligations In order to effect s. 153(1.01) withholding, certain employers have some shares redeemed immediately following the exercise of employee stock options in order to raise the requisite source deduction amount – and to accomplish this, the stock option agreements are amended to give the employer the right to redeem the shares in part. ...

. … Where applicable, the distribution would be subject to a withholding tax pursuant to subsection 212(11) and paragraph 212(1)(c)…. ...

. … Where applicable, the distribution would be subject to a withholding tax pursuant to subsection 212(11) and paragraph 212(1)(c)…. ...

In the situation described … those two conditions are not satisfied. ...

That position is supported … in First Vancouver Finance. ...

. … See summary under s. 212.3(2). ...