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The concern expressed in the Explanatory Notes- that the current rules allowed the accrued gain from the acquisition of shares or debt of a Canadian-resident corporation to be deferred indefinitely while still allowing a Canadian-resident corporation to have use of the underlying property (eliminated altogether through a subsequent reorganization) – might have been addressed more narrowly by requiring that the capital property be foreign capital property. ...

., where two controlled foreign affiliates (“CFA1” and “CFA2”); of Canco wholly-own LP, which wholly owns “CFA3,” with CFA3 incurring interest expense that is otherwise deductible in computing its FAPI relative to LP – given, inter alia, that LP is not a “taxpayer" (as defined in draft s. 18.2(1)) for EIFEL purposes and draft s. 95(2)(f.11)(ii)(A) provides that s. 18.2(2) does not apply for purposes of computing FAPI of a foreign affiliate. ...

See also 2015-0570021E5 F. ­­­­­­­­­­­­­­­­­­­­­­­­ ...

No deemed payment of dividend on emigration (p. 9) The position in 9640475 – that s. 128.1(4)(b) would apply to tax the individual on the emigration as if the declared and unpaid dividend had been paid- appears to be incorrect. ...

When so used, advantages of the EPSP over an EBP trust include that the increase in the shares’ value from their acquisition can be received by the employee as a capital gain (in contrast to employment income under an EBP) and dividends and capital gains generated by the EPSP can retain that character when allocated to an employee – and the employer’s deduction of contributions to an EPSP is more immediate and straightforward (i.e., no need for the trustee to determine the employer’s deduction nor is it offset by income earned in the trust). ...

Likely non-application of s. 75(2) where shares issued to s. 7(2) trust are from treasury (p. 24) Although one of the s. 8(12) requirements is that the trust have disposed of the share to the corporation that issued the share to the trust, CRA has indicated that a reversion engaging s. 75(2)(a)(i) requires the transferee to have owned the property before it was held by the trust – so that s.75(2) should not apply where the corporation’s shares were issued directly from treasury to the trust (see 2006-0218501E5, 2007-0243241C6 and 2009-0317641E5 regarding the situation where a trust subscribes for shares of a corporation for FMV consideration). ...

Larry Nevsky, Brian Kearl, Aaron Chai, "Unexpected EIFEL Issues and Uncertainties", Draft 2024 CTF Annual Conference paper-- summary under Clause 95(2)(f.11)(ii)(D) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(f.11)- Subparagraph 95(2)(f.11)(ii)- Clause 95(2)(f.11)(ii)(D) Issues with s. 95(2)(f.11)(ii)(D) rule (pp. 12-13) S. 95(2)(f.11)(ii)(D) provides, respecting s. 95(2)(f)(ii) (but not (i)) amounts included in the RAIFE of a CFA of a Canadian taxpayer for a taxation year, for a denial of such RAIFE amounts otherwise deductible in computing FAPI in proportion to the overall denial (if any) computed under s. 18.2(2) – so that deduction of the RAIFE of the CFA is potentially subject to the same proportionate denial as for its Canadian parent in respect of the parent’s IFE (although note that s. 95(2)(f.11)(ii)(D) does not apply to an excluded entity). ...

Peakhill Capital Inc. (2024 BCCA 246) …. ...