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If Y and Z argued that s. 104(13) did not apply to them because no amount was payable to them in the year, CRA would apply s. 56(2) or (alternatively) s. 105(1) to include the dividend amounts in their income – but without any s. 104(6) deduction to the Trust. ...

IV(6) – and, similarly, LLC1 Itself would be considered to be deriving such income as a qualifying person if it had chosen to be treated as a corporation. ...

. … [T]he reassessments would be attributable to FAPI arising directly from the contribution by the Taxpayer of the Marketable Securities to ForeignCo which, in our view, would be a "transaction" between Holdco and ForeignCo referred to in subparagraph 152(4)(b)(iii) that it would be reasonable to consider as relating to the reassessments for purposes of subparagraph 152(4.01)(b)(iii). ...

Before addressing whether such payments were deductible under s. 32.1 or 9, the Directorate stated: [P]aragraph 7(3)(b) does not apply to prohibit a deduction for Canco’s PSP expenditures ….. ...

. … [A]mounts invoiced by Parentco to a particular entity are based on the employee’s employer as at the grant date. ...

. … Furthermore, to the extent that the conditions in paragraphs 86.1(2)(e) and (f) have been satisfied and the Distribution was made in respect of all of the Common Shares of the capital stock of Parentco owned by the particular taxpayer at the time of the Distribution, it is our view that the Distribution is an eligible distribution to that taxpayer within the meaning of subsection 86.1(2). ...

Before concluding that it would “generally consider emergency government assistance, including assistance from provinces and municipalities, directly related to COVID-19 to be an extraordinary item,” but that this would include “COVID-19-related government assistance … to the extent that it replaces or is meant to replace normal or recurring government assistance,” the Directorate stated: Generally, we would expect extraordinary items to meet all three of the following characteristics: a) Not be expected to occur regularly or frequently within several years Grants or other government assistance that an entity is eligible to receive on a regular or reoccurring basis would not meet this criteria. b) Not typical of the normal activities or risks inherent in the normal operations of the entity Consideration should be given to the nature of the services or products offered by an entity and the normal environment in which it operates. c) Primarily out of the control of owners or management Consideration should be given to the extent that inflows are influenced by the decision of owners or management. ...

If the RSUs are settled in Year Four, more than three years after the end of the year in which these services were rendered, the paragraph (k) exception would not apply …. ...

The reason is that (a)(ii) of the ERDTOH definition only adds the Part IV tax if it generated a dividend refund to the connected payor out of its ERDTOH – and since the connected payor by assumption had not yet transitioned to the ERDTOH/NERDTOH regime, this would not be possible. ...

“[I]t is not necessarily the case that a qualifying property of an eligible entity will always conform to its legal title” – for example, the leasehold interest of a commercial tenant may represent only a portion of the legal title of the property. ...