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Technical Interpretation - External summary

5 August 2022 External T.I. 2021-0877051E5 F - TOSI and excluded amount -- summary under Related Business

(a)(ii) of that definition, that prima facie, the mere fact of M-1 and C-1 acting as directors of Investco would not be sufficient in itself to consider that they were actively involved, on a regular basis, in the activities of Investco's business,” but that the “ownership test” in s. ...
Technical Interpretation - External summary

30 October 2014 External T.I. 2013-0488881E5 - Upstream Loan -- summary under Subsection 90(9)

On 20 June 2013 FA2 made the $1,500 "FA2 Loan" to Canco for 10 years but FA2 was wound-up into FA1 on 20 February 2014. ...
Technical Interpretation - External summary

3 December 2015 External T.I. 2015-0593941E5 F - Allocation of the safe income on hand -- summary under Paragraph 55(2.1)(c)

. With a dividend in the order of magnitude of $35,000…we could conclude that the reduction is significant or the increase in cost is significant. ...

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