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. … 2012-0456221R3 is therefore still valid … ...

. … The CRA does not consider that the use of post mortem transactions to eliminate the capital gain arising on the death of the beneficiary spouse in order to limit double taxation at the trust level results in a situation of [GAAR] abuse …. ...

CRA responded (TaxInterpretations translation): … (a) As indicated in response to question 7 at the Corporate Management Tax Conference Roundtable of the Canadian Tax Foundation in 1992, there is no hard and fast rule for determining what, in a particular situation, is considered reasonable respecting the choice of a currency in which the surplus accounts of a foreign affiliate are to be maintained for purposes of ITR subsection 5907(6). ... If an examination of these criteria, as well as others considered to be appropriate, permits a determination that use of the Canadian dollar presents a fair picture ["image juste"] of the surplus account balances of the foreign affiliate, we will consider that such use is reasonable in the circumstances. … (b) Provided that the use of the Canadian dollar is reasonable in the circumstances and that there is no retroactive tax planning involved, we will accept that the surplus account balances of a foreign affiliate for its taxation years terminating before the entry into force of the amendments effected by the 2012 Act [on 26 June 2013] are to be converted into Canadian dollars using the "relevant spot rate," as that expression is defined in subsection 261(1), at the first day of the first taxation year of the foreign affiliate commencing after 18 December 2009…. ...

Under s. 248(35)(b)(i), the FMV of the policy for gift receipting purposes was the lesser of its FMV ($100,000) and its ACB ($50,000) – except that under s. 248(36), for s. 248(35) purposes, the cost or adjusted cost base, of the property to ACo immediately before the gift could be deemed to equal the lower of its cost and adjusted cost base to Mr. ... Notwithstanding that proposed subsection 248(36) was not similarly amended, it remains our view that the ACB of an interest in a life insurance policy, as defined in subsection 148(9), is generally a reasonable proxy for the "cost" of an interest in a life insurance policy for purposes of subsection 248(36). … [S]ince ACo acquired the life insurance policy less than three years before it intends to donate the policy, the proposed gift would meet the condition in subparagraph 248(35)(b)(i) and be subject to the deemed FMV rule in subsection 248(35). ...

…[T]he fact that, in situation (a), the payment received by the taxpayer in 2017 is more than the payment required to extinguish the tax under Part X.1 … [and] in situation (b), the taxpayer is not subject to tax under Part X.1 before receiving the payment would not in and of itself preclude the application of subsection 146(8.2). …[U]nder [s. 146(8.2)(e)], if undeducted premiums have resulted in an overcontribution then, subject to paragraph 146(8.2)(f), the deduction will only be possible if such excess contribution was in fact made inadvertently. … [I]n Situation (a), the $26,010 amount paid by the taxpayer to his or her RRSP after receiving the $30,000 amount would generally be deductible under subsection 146(5). ...

Example 2 Same as example 1, except that the transferor had no unclaimed CGE at the year end – resulting in the CGE deemed to have been claimed only re $50,000 of the capital gains. Example 3 Same as Example 1, except that the transferor had $10,000 of unclaimed CGE at the year end – resulting in the CGE deemed to have been claimed only re $70,000 of the capital gains. ...

Subco used $2,000 borrowed from a third party to acquire assets with a cost amount of $3,000 – which subsequently lost all their value. ... Parentco would essentially have taken two deductions for the same loss of $1000 – first the $1000 loss on the Subco shares under 50(1), and an additional loss of $1000 on the assets of Subco. ...

X of his 100 Opco shares to Holdco X, their safe income was retained and that, since the loan was “was repaid out of the corporation's earned or realized income … that income cannot be viewed as contributing to the unrealized gain on the common shares of the capital stock of Opco” – so that the relevant safe income of the 100 Opco common shares of Holdco X (and also of Holdco Y) was $50,000. ...

. … [I]t should be noted that subsection 104(24) does not alter the ordinary meaning of the term "payable" nor does it specify when an amount becomes payable. ... However, this deeming rule does not apply if the amount was paid to the beneficiary in the year or if the beneficiary was entitled in the year to enforce payment of it. … [A] taxpayer does not have to be a beneficiary of a trust throughout the taxation year of the trust in which an amount becomes payable to the taxpayer in order for that amount to be included in computing the beneficiary's income pursuant to subsection 104(13)”.... ...

. … [S]ubsection 7(2) does not serve to deem the existence of an agreement to issue or sell shares for the purposes of section 7 where such an agreement does not, in fact, exist. … [W]hen he becomes a discretionary beneficiary of the Trust on January 1, 2022, Mr. ...