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There is no provision … that allows for a different calculation … in this situation. ...

After noting that the s. 123.4(2) deduction is determined by applying the general rate reduction percentage for the year to the corporation’s “full rate taxable income” for the year, CRA stated: Where a corporation is a CCPC, full rate taxable income is determined under paragraph (b) of that definition … [and] is its taxable income subject to tax under subsection 123(1) reduced by, inter alia, its aggregate investment income as defined in subsection 129(4). ... There is no provision … that allows a charitable deduction to be taken into account in computing a corporation's aggregate investment income ...

CRA referred to the statement in Canadian Wirevision that “goods … is used in the common parlance of merchandise or wares, or, to put it in legal jargon, tangible moveable property” and to various dictionary definitions generally referencing “all tangible, moveable, personal property intended for sale,” Furthermore, CRA’s view that residential condominiums, being real estate, are not “goods” under s. 95(3)(b) was consistent with the balance of the wording of s. 95(3) – for instance s. 95(3)(a) excluded the transportation of goods. ...

In determining whether a taxpayer or a partnership has made or obtained records or documents that provide a description that is complete and accurate in all material respects of the items listed in subparagraphs 247(4)(a)(i) to (vi), the CRA will continue to rely on the guidance found in the … TPM-09 …. ...

. … [I]f there are very few transactions (e.g. annual, semi-annual or quarterly payments), the use of the applicable daily exchange rates will be required. As a general rule, the CRA will not accept the conversion of a gain or loss on the disposition of a capital property using an average exchange rate. … Consequently, the daily exchange rate for the particular dates should be used to determine, in Canadian dollars, the adjusted cost base ("ACB") of such property and any proceeds of disposition from its disposition. ...

What amount is added to the capital dividend account (CDA) of the corporation if the non-taxable portion of the trust’s capital gains is paid out to other beneficiaries – and when does the addition occur? ... The ½ distributed that was the non-taxable portion of the trust’s capital gains, would be added to the corporation’s CDA, net of any applicable amount of the corporation’s allowable capital losses. ...

20 June 2023 STEP Roundtable Q. 12, 2023-0959591C6- Corporate Beneficiary and CDA-- summary under Subsection 104(21) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(21) s. 104(21) designation can be made re distributing the taxable half of a trust capital gain to a corporate beneficiary – who receives no CDA addition An inter vivos Canadian resident trust pays an amount equal to its net taxable capital gains for the year to a Canadian private corporation that is a beneficiary and designates that amount pursuant to s. 104(21). ... (a)(i.1) of the capital dividend account definition, there would be no addition to the corporation’s CDA – whereas there would be such an addition if both portions of the capital gains were distributed to the corporate beneficiary. ...

Furthermore … the transfer of the employee's rights in the DSU Plan could indirectly allow the individual to access the value of the individual's rights before one of the times specifically identified in paragraph 6801(d)(i) … which would also contravene the requirements of paragraph 6801(d). ...

The indefeasible vesting exception to such deemed dispositions in s. 108 – trust – (g) did not apply because of the exclusion for spousal trusts in (g)(i) thereof. ...

. … [S]uch fees would be fully deductible pursuant to paragraph 20(1)(bb) provided that they are reasonable in relation to the services received and that they are in respect of the administration or management of shares or securities. ... Accordingly, the principal business of a person carrying on a financial services business and offering insurance, investment and lending services is, inter alia, providing services in respect of the administration or management of shares or securities even if the activities relating to those investment services alone represent … less than 50% of the person's total activities. … [A] person licensed by one of the Canadian Securities Administrators to advise on the advisability of buying or selling certain shares or securities or to provide services in respect of the administration or management of shares or securities may be presumed to satisfy the "principal business" condition. ...