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This Proof of Income can be viewed and printed by a taxpayer using the "My Account for Individuals" option …. … [W]ith respect to capital cost allowance that may have been claimed by a taxpayer in prior years, this information could possibly be included in the Proof of Income mentioned above. ...

Consequently … upon Mr. X's death, subsection 70(5) would apply …. ...

Thus, to the extent that the applicable corporate law allows the corporation to pay a separate dividend on a series of shares of a given class of its capital stock … the election provided for in subsection 83(2) could be made with respect to the dividend that became payable on that series. Furthermore … if it were the case that certain reorganizations or conversions of shares carried out through a transaction, or as part of a series of transactions, one of the main purposes of which is to enable shareholders to receive capital dividends, then the application of subsection 83(2.1) should be considered. ...

[Reg.] 2101 … requires the corporation to file with the Minister, inter alia, the prescribed form and a certified copy of the resolution …. ...

Is Father not considered to have made a contribution because the loan qualified as an arm’s length transfer on the basis that “it is reasonable to conclude that none of the reasons … for the transfer is the acquisition at any time by any person or partnership of an interest as a beneficiary under a non-resident trust”.? ... Such a conclusion would be highly unlikely given his relationship to them – so that he would be considered to have made a contribution to the trust, he would be a resident contributor and the trust would be deemed to be resident for the purposes listed in s. 94(3)(a). ...

This loan will not be considered to be a contribution by him (so that it will not cause the trust to be resident for various purposes under s. 94(3)(a)) if it is an “arm’s length transfer,” whose definition relevantly requires that it reasonably be considered “that none of the reasons … for the transfer is the acquisition at any time by any person or partnership of an interest as a beneficiary under a non-resident trust.” ... CRA indicated that such a conclusion would be highly unlikely given his relationship to them – so that his loan would be considered to be a contribution to the trust causing him to be a resident contributor and the trust to come within s. 94(3)(a). ...

CRA stated that it was “not prepared to take an administrative position to consider that subsection 247(7) would apply in respect of the loan between the FA and LP ….” ... Further, “adopting the requested administrative position could potentially facilitate the use of structures using hybrid entities to achieve a tax benefit. … As a general rule, taxpayers should expect that administrative relief requests that appear to potentially facilitate such planning will be denied by the CRA. ...

S. 20(1)(j) refers inter alia to “such part of any loan or indebtedness repaid by the taxpayer in the year as was by virtue of subsection 15(2) included in computing the taxpayer’s income for a preceding taxation year (except to the extent that the amount of the loan or indebtedness was deductible from the taxpayer’s income for the purpose of computing the taxpayer’s taxable income for that preceding taxation year) ….” ... Consequently, X having claimed the s. 20(1)(ww) deduction should not preclude X from subsequently claiming the s. 20(1)(j) deduction when the loan is repaid – and that this appears to be the right policy result. ...

CRA noted that the foreign incorporation produces a tax benefit consisting of the “avoidance” of the refundable tax under s. 123.3, and the generation of the s. 123.4(2) deduction, and then stated: … If the purpose of such a transaction were to avoid CCPC status in order to defeat the purpose and intent of various anti-avoidance rules applicable to investment income, including section 123.3 and subsection 123.4(2), the CRA would consider, depending on the circumstances, application of the GAAR …. ...

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 …. ...