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However, practical solutions to these types of technical issues exist and therefore the CRA does not consider that a flexible approach is necessary in the[se] circumstances …. ...

(a), the joint designation referred to therein was required to “be made jointly by the deceased annuitant's legal representative and the Spouse” so that “in order for the designation to be valid, the Spouse must be alive at the time the joint designation is made,” and so that a “joint designation made … [with] the deceased Spouse's legal representative would not satisfy this requirement.” ...

It could, however, assess the resident beneficiary for an amount not exceeding $100,000 on December 31, 2022 given that the conditions in s. 94(7) were by assumption satisfied for the 2020 year – and this was so even if s. 94(3) had ceased to apply to the trust for its 2021 or 2022 taxation year. ...

S. 104(24) would be satisfied if the full $350,000 was paid to her in cash, and also would be satisfied through the estate issuing the demand note “to the extent that the issuance of the note was permitted by the will and … the demand note was unconditional.” ...

4 June 2024 STEP Roundtable Q. 8, 2024-1007841C6- Disposition of Property Held in a Bare Trust-- summary under Subparagraph 150(1.1)(b)(ii) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.1)- Paragraph 150(1.1)(b)- Subparagraph 150(1.1)(b)(ii) a disposition by a bare trust, or the trust’s winding-up, generally is not a disposition under the ITA A bare trust (not described in (a) to (e.1) of s. 108(1) – trust) holds no property in the year other than a Cdn.$10,000 government bond and money, not exceeding Cdn.$50,000 in the year, so that it satisfies s. 150(1.2)(b). ...

Y could generally be allowed …. ...

. … [The] trust structures designed to purposely invoke attribution pursuant to subsection 75(2), with a view to avoiding the payment of tax on extracted corporate dividends …typically involves two Canadian corporations and a trust that acquires shares in one of the corporations ("Corp A"). ...

. … [T]these entities have many characteristics in common with "limited liability companies" ("LLCs") that exist in the U.S., which are generally considered to be corporations for the purposes of the Act, but that they also have many characteristics in common with the various forms of partnerships.... ...

Response After summarizing the purpose requirement in Reg. 6205(2)(a)(i), and the requirement in Reg. 6205(2)(a)(i)(III) that each beneficiary not deal at arm's length with the Original Holder, and noting that each participating share would be required to satisfy Reg. 6205(1), and before noting the requirements of Reg. 6205(4)(c)(i) and (ii), CRA noted (Tax Interpretations translation) that, respecting the amalgamation, Reg. 6205(4)(c) " creates a presumption under which preferred shares issued by the New Corporation to each Original Holder qualify as a Prescribed Share. ...

. … The result...is that the tax-exempt margin made it possible for part of Oka’s surplus to be distributed to the appellants tax-free in a manner contrary to the object, spirit or purpose of section 84.1 of the Act. ...