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. … [I]f the trust continues to exist after deregistration and the shares of the cooperative are not transferred to the annuitant in the year of deregistration or are transferred in a year subsequent to the year in which subsection 146(12) applies, we are of the view that no withholding tax is required under the application of the provisions of the Act and Regulations since no payment is made on deregistration and in the year of deregistration. ...

. … [U]nlike paragraph 251(5)(b), the definition of term preferred share does not contain the exception that applies where one or more of the rights referred to in that provision cannot be exercised at that time because the exercise of the rights in question depends on the death, bankruptcy or permanent disability of an individual. ...

. … [T]he Court's judgment had the effect of crystallizing the amount receivable and making it payable to the Taxpayer retroactively from the date of the summons. ...

3 November 2004 Internal T.I. 2004-0083791I7 F- Paragraphe 44.1(2)-- summary under Subsection 44.1(8) Summary Under Tax Topics- Income Tax Act- Section 44.1- Subsection 44.1(8) pre-condition of carrying on business not satisfied / general overview provided A newly-formed corporation used its cash share subscription proceeds almost entirely to purchase a piece of land for which, to date, a required zoning change has not yet been obtained. ...

Regarding whether the Minister could reassess XCO directly to change the partnership income allocated to it, the Directorate stated: [T]he Minister could reassess pursuant to subsection 152(4) at the level of the XCO general partner, in respect of the tax that would be payable by XCO for the Particular Taxation Year, in order to, inter alia, modify the amount of its share of the income from BCOM that was included in the computation of its income … without a determination being made at the level of BCOM pursuant to subsection 152(1.4), and without assessments at the level of BCOM partners being made pursuant to paragraph 152(1.7)(b). ...

The Rulings Directorate ruled that the licence granted by the qualified corporation to the U.K. corporation did not constitute a disposition by it of the copyright in the film or video production (a position which CCRA now confirmed), and also ruled that s. 125.4(4) would not apply if the only investors were the U.K. corporation, the U.K. partnership or the members of that partnership – so that the Canadian Film or Video Production Tax Credit would not be denied to the qualified corporation solely because of the above facts. ...

CRA stated: [P]aragraph 94(2)(t) … applies to expunge the contribution after the time of the sale (i.e., from the time of the sale forward, the contribution is considered to have never occurred). ...

. … [F]or U.S. income tax purposes, the Canadian Branch profits of LLC3 are considered to be derived by the first entity in the corporate chain which is not treated as a fiscally transparent entity for U.S. income tax purposes. ...

Given the potentially significant differences in both the amount and timing of the reimbursement payment as compared to the actual contributions made by Parentco … the reimbursement payments are not equivalent to Parentco’s contributions to the EBP, and thus cannot be considered to be a proxy for those contributions. ...

If it is determined that the TPRs were due to an error … the TPRs for all of the taxation years could be accepted. ...