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

Rulings Including that s. 107(2) will apply to the distribution from the Trust of the Real Property to the Beneficiary such that: pursuant to s. 107(2)(a) the Trust will be deemed to have disposed of the Real Property for its cost amount, the Beneficiary will be deemed under s. 107(2)(b) to have acquired it at the same amount and under s. 107(2)(c) to have disposed of part of its capital interest for that amount minus the eligible offset amount, being the amount of the assumed debt, and pursuant to ss. 107(1.1), 107(1)(a), and s. 108(1) – “cost amount”, the adjusted cost base of the part of the capital interest in the Trust to the Beneficiary, immediately before the disposition of such part of the capital interest, will be deemed to be the total of all amounts each of which is the cost amount to the Trust of the distributed properties. ...

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).” ...

After quoting the statement in Ludco that “courts should objectively determine the nature of the purpose, guided by both subjective and objective manifestations of purpose,” CRA indicated that Ludco followed the purpose test in Symes, and the Symes / Ludco test (consistently with many other decisions) constitutes the benchmark of purpose. ...

21 November 2017 CTF Roundtable Q. 6, 2017-0724071C6- Circular calculations Part IV tax-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) where Holdco receives a dividend subject to refundable Pt IV tax and to s. 55(2), two different dividends should be reported for Pt IV and s. 55(2) purposes Holdco receives a dividend of $400,000 that is subject to Part IV tax of $153,333 (38.33% of $400,000) equalling the connected payer’s dividend refund and, in turn, pays a dividend to its shareholders resulting in a refund of the Part IV tax – so that the dividend received by Holdco is subject to s. 55(2). ...

Now a further estate freeze is effected under which Initial Trust exchanges its shares for preferred shares under s. 51 and a newly-formed discretionary family trust (“New Trust” – also having grandchildren and family corporations as beneficiaries and with a different unrelated individual as the third trustee) subscribes for new non-voting common shares. ...

(c)(i)(A) of "total charitable gifts," CRA noted respecting the first condition that “where subsection 118.1(5) applies to a gift, the gift is generally deemed to have been made by the individual's estate at the time the property to which the gift relates is transferred to the qualified done,” and that s. 118.1(4.1) “provides that subsection 118.1(5) applies … to a gift made by the individual’s estate,” and then stated: If, as you stated, the transfer of ownership of the interest to the Private Foundation was made within three years of the death, subsection 118.1(5.1) would apply because the property that was the subject of the gift (the interest in the policy) was acquired by the estate on and as a consequence of the death. ...

CRA reasons (in its summary) The definition of a "participating debt interest" refers to interest "that is paid or payable on an obligation, all or any portion of which …". ...

Parent then amalgamated with Target and the Subco shares were bumped under s. 88(1)(d) – but with the bump amount being reduced by any Subco surpluses described in Reg. 5905(5.4). ...

X (Corporation B – the ultimate funder) with that bank. In finding that the back-to-back loan rules in s. 15(2.16) et seq. deemed Ms. ...