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. … The CRA does not have its own method for computing the FMV; this computation is based upon the facts known on the valuation date, to which the principles and standards of the Canadian Institute of Chartered Business Valuators are applied. ...

Under the Canadian domestic situs rules, the gain would have a U.K. source so that there would be no Canadian foreign tax credit for the Australian tax – but this is remedied by Art. 22(2) of the Canada-Australia Treaty (broadly similar, for example, to Art. 24(3) and 21(3) of the U.S. and U.K Treaties, respectively), which provides that income or gains of a Canadian resident which are taxed in Australia in accordance with Art. 13 of the Treaty are relevantly deemed to be sourced in Australia. ...

. … Accordingly, the taxable dividend deemed to be received would need to be reported in the individual's final personal income tax and benefit return. ...

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 6, 2020-0851631C6 F- Options d’achat d’actions- disposition au décès-- summary under Paragraph 7(1)(e) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(e) s. 110(1)(d.01) gift deduction is unavailable against a s. 7(1)(e) stock option benefit S. 110(1)(d.01) provides for an additional ½ deduction (so as to result in a nil taxable income inclusion) where the s. 110(1)(d) deduction was available for a s. 7(1)(a) stock option benefit and there is a timely gift of the optioned security to a qualified donee. ...

CRA, in its response, added: 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 ...

. … Except in situations of indirect arrangements or loans referred to in subsection 17(2), section 17 generally does not apply to an amount that is owed to an individual. ...

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. ...

Without referring specifically to s. 16, CRA indicated that this position was contrary to Shell Canada, which found that absent a specific provision to the contrary or sham, the taxpayer’s legal relationships must be respected – so that withholding tax would not apply in such a situation absent a finding of sham or the application of a specific provision, e.g., s. 245 or 247. 5 September 2020 IFA Roundtable, Q.2 is similar. ...

CRA noted that if the trust elects in its T3 return for its first taxation year, then it will no longer fall within the scope of s. 104(4)(a) – and because it did not apply, CRA would consider that the settlor’s death would not be relevant for the purposes of the preamble to s. 104(13.4). ...

Suppose that a lump sum from the pension plan of the deceased is not received by the estate until beyond this 36-month period – and the executor is unable to distribute the income to the sole beneficiary before the end of the year of receipt. ...