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CRA indicated that it was not prepared to extend its policy on farm-in arrangements to this situation (given that “carrying out the work on the claims does not give a right in the claims but potentially only an option to acquire them”), stating: Consequently … the amounts paid to carry out the work on the claims of Corporation B would be added to the cash payments provided for in the agreement and would be considered part of the overall consideration given by Corporation A to acquire a property. ...

In this type of arrangement (or one where the employee only receives advances during the leave – in which case, it is not within the DSLP rules), the employee is entitled to a s. 8(1)(n) deduction as the advances are “repaid” (i.e., out of reduced pay cheques following the return to work). ...

. … [Respecting] the last condition…provided that at the time FA Finco receives the amount of penalty, FA Holdco continues to hold the shares of FA Opco that constitute a source of income for FA Holdco, the fourth condition of Clause D would be satisfied. ...

. … …[T]his type of deduction would not be covered by any of the exceptions set out in the definition of "annuities" in Article 18, paragraph 5….. ...

XXIX(5) of the Canada-France Convention: [or as non-business income tax for the purposes of section 126]: CSG ("contribution sociale généralisée" ["general social contribution"]) CRDS ("contribution pour le remboursement de la dette sociale " [contribution for the repayment of the social debt]) Sécurité sociale vieillesse [old age social security] (retirement) Pole emploi (similar, in your opinion, to Employment Insurance) Retraite complémentaire [supplementary pension] (according to you, mandatory)? ...

The result is the same whether the circular calculations begins with the $800,000 dividend paid by one of the corporations, or the other …. 4 th Situation This is identical to the 3 rd, except that, in 2004, ABCco paid a taxable dividend of $100,000 to its parent. ...

. … [Y]our mother did not ordinarily inhabit the residence during the years XXXXXXXXXX to XXXXXXXXXX. ...

Specific clauses in the trust deed providing that certain types of payments will constitute income to the trust are acceptable- the “fact that the trust deed provides that certain types of payments will constitute income does not, in and of itself, determine whether the conditions of subsection 104(18) … are satisfied, including the condition referred to in subsection 104(18)(c).” ...

However … under subsection 256(2), Aco could elect in prescribed form for the 2004 taxation year not to be associated with either Bco or Cco. ...

CRA responded: [S]ubsection 256(2) would not apply in the particular taxation year … because Aco and Bco would be associated with each other in the particular year but for subsection 256(2). ...