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CRA stated: Subsection 148(8) … provides that, if an interest of a policyholder in a life insurance policy (other than an annuity contract) is transferred to the policyholder’s child for no consideration and a child of the policyholder or a child of the transferee is the person whose life is insured under the policy, the interest is deemed to have been disposed of by the policyholder for proceeds of the disposition equal to the adjusted cost basis of the interest immediately before the transfer, and to have been acquired … at a cost equal to those proceeds. ... We are not certain that the results described above are consistent with the intended policy of subsection 148(8), and it is therefore our intention to bring the matter to the attention of the Department of Finance …. ...

29 May 2018 STEP Roundtable Q. 9, 2018-0744111C6- Vested Indefeasibly-- summary under Paragraph (g) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(1)- Trust- Paragraph (g) meaning of vested indefeasibly For purposes of the 21-year deemed disposition rule, a trust does not include a trust "all interests in which … have vested indefeasibly". ... CRA also referenced Boger Estate, which indicated that vesting occurs when there is no condition precedent to be fulfilled before the gift can take effect, and the persons that are entitled are ascertained and ready to take possession – there can be no prior interest in existence – and that a vested interest becomes indefeasible where there is no condition subsequent, or determinable limitation set out in the grant. ...

The Trust and its beneficiaries then used their sales proceeds to subscribe for the shares of a newly-incorporated holding company (Holdco): Trust – 50% of the Holdco shares; Mr. and Mrs. X – 20% each; and Child X and Y – 5% each). Holdco generated $150,000 from investing these funds in the stock market and paid a $100,000 dividend pro rata to its shareholders, so that Child Y received a $5,000 dividend. ...

The beneficiaries then used their sales proceeds to subscribe for the shares of a newly-incorporated holding company (Holdco): Trust – 50% of the Holdco shares; Mr. and Mrs. X – 20% each; and Child X and Y – 5% each). Holdco generated $150,000 from investing these funds in the stock market and paid a $100,000 dividend pro rata to its shareholders. ...

CRA stated that “the principal question is whether the payment is made as a consequence of the individual's death” and, in addition to referencing the s. 248(8)(b) rule, noted that “paragraph 248(8)(a) provides, in particular, that a transfer … of property made … as a consequence of [the taxpayer’s] will is considered to be a transfer … made as a consequence of the death of the taxpayer.” ...

CRA stated: … [W]here the tenant of a leased property receives from the owner of that property an amount to obtain the termination of its lease … such an amount represents proceeds of disposition of part or all of the leasehold interest. … The definition of "principal residence" in section 54 provides that a leasehold interest may be a principal residence. ...

11 October 2019 APFF Roundtable Q. 6, 2019-0812651C6 F- CDA and wind-up of a subsidiary-- summary under Paragraph 87(2)(z.1) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(z.1) IT-126R2 applicable in determining when CDA of sub is added to parent’s CDA Holdco, which has a calendar taxation year-end, commences the winding-up of its wholly-owned subsidiary (Opco – which has a June 30 taxation year-end) on March 31, 2018 with an authorizing resolution, and the Opco assets and liabilities are distributed and assumed on that date. ... CRA responded: [In] IT-126R2, the CRA states that it considers that where the formal dissolution of a corporation is not complete but there is substantial evidence that the corporation will be dissolved within a short period of time, for the purpose of subsections 88(1) and (2) the corporation is considered to have been wound up. … … The determination of when a corporation is wound up for the purposes of subsections 88(1) and 88(2) requires consideration of all facts and circumstances relevant to a particular situation. ...

. … [E]xpenditures in respect of research in determining economic viability may be considered to be on income account.... ... If so, it is denied current deduction …. … The postponement or cancellation of a project does not alter the nature of an expense incurred in connection with such project. ...

. … [A]ny amounts that the trust pays or makes payable to beneficiaries must be authorized or permitted by the trust instrument and the applicable law … [and] we have assumed that the amounts that are paid or payable to the beneficiary, and designated under subsection 104(21), are for the beneficiary’s own account and benefit …. ...

CRA responded: (a) … In a context similar to that described in the statement of this question, the CRA generally accepts that shareholders may give their concurrence in advance, through undertakings under the various sale agreements, to the making of [the] election …. ... However, if an excessive capital dividend is identified in the year it is paid or payable, the corporation will have to file additional T5 slips by the last day of February of the following year …. ...