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However, on the death of Daughter2, ½ of the Fund property had been distributed in accordance with the Fund terms to her issue. ...

CRA indicated that since Canco and Holdco each held the USco shares directly for a portion of their 2023 taxation year, each would be a reporting entity that was required to file a T1134 for their 2023 taxation year – however, as a related group with the same year end, and using the same functional currency, they could designate one of them as their representative to file a single T1134 information return with the required information for both. ...

X's daughter purchased the shares from a person with whom she was dealing at arm's length … the ACB of those shares should not be reduced by paragraph 84.1(2)(a.1), for the purposes of section 84.1. ...

. …. If, in the case described, there in fact is an allocation of capital gains of the SEC to its partners, we believe it would be difficult to maintain that they do not retain their character in the hands of the latter, including the Limited Partner.... ...

. … [G]eographic coherence [also] is required under the Treaty. ...

Holdco B Sub will be wound–up – and then dissolved. The two Notes will be set-off. ...

Holdco B Sub will be wound–up – and then dissolved. The two Notes will be set-off. ...

. … Therefore…paragraph 248(28)(a)… applies to remedy the situation and avoid double taxation of the same amount. ...

Rockies Corp, 2005 DTC 289) that "a corporation may opt for whichever instalment method under paragraph 157(1)(a) that it wishes, regardless of the instalment method that is deemed by subsection 161(4.1) to have been used for purposes of computing the corporation's interest in respect of unpaid or late instalments," CRA stated that "a corporation's functional currency election…does not hinder its ability to choose…[an] instalment method under paragraph 157(1)(a)," stated that it "will not consider the use of either the First Instalment Base Method or the Second Instalment Base Method where a reporter's Total EFC Instalments [the total required instalments, as converted to the EFC] using the respective instalment method exceed the reporter's EFC Taxes Payable for the year," and that it was appropriate "that each assessment of the CAD Taxes Payable of a functional currency reporter…[use] the instalment method that gives rise to the least amount of CAD Taxes Payable" – so that when re-determining the CAD Taxes Payable for a particular taxation year as a result of a s. 111(1)(a) deduction of a subsequent year's loss, the same instalment method that was originally used for the particular year is not required to be used to recalculate the CAD Taxes Payable. ...

Pubco (acting through a branch in Country 1 – assumed here to be Luxembourg) will subscribe with cash for common shares and/or mandatorily redeemable preferred shares ("MRPS") of Finco. ...