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After the property had changed hands a number of times, it was acquired by ACo, which recommenced limited production, but then ceased production as the projected grade was not achieved, and ACo put the property on care and maintenance, but continued exploration work, with the focus on near-surface targets that were outside the mine footprint – but then also drilled from an underground platform. ... Ruling Re the expenses of the proposed program qualifying under s. 66.1(6) – CEE- para. ...

2017 Ruling 2017-0699201R3- Cross-border Butterfly-- summary under Paragraph (b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(1)- Permitted Exchange- Paragraph (b) cross-border butterfly including preliminary transfer of DC to foreing parent to come within “permitted exchange” CRA ruled on a cross-border butterfly which entailed assets of the “Transferred Business” being transferred indirectly to a wholly-owned non-resident subsidiary (Foreign Spinco) of a non-resident public company (Foreign Parentco) or to a wholly-owned non-resident subsidiary of Foreign Spinco (Foreign Spinco Sub) – with a view to the shares of Foreign Spinco being dividended out to the shareholders of Foreign Parentco at the transactions’ completion. One of the indirect assets of Foreign Parentco was a Canadian corporation (DC) which held the Canadian portions of both the Transferred Business and the “Retained Business” – hence the need for a cross-border butterfly. ...

“However, no property will be acquired by a person described in subclause 88(1)c)(vi)(B)(I), (II) or (III) in the course of the following series: the transactions or events which include the amalgamation …. or winding-up ….” ...

(This step will “ensure that US Parent’s status as a holding company for … net worth … tax is not jeopardized by the completion of the Proposed Transactions. ...

The DSI of the transferor corporation (“Transferor”) that has accrued on the shares of its capital stock held by shareholders other than the transferee corporation (“Transferee”), determined immediately after the reorganization, will be calculated in accordance with the following formula: DSI on shares of capital stock of Transferor held by all shareholders immediately after the reorganization = DSI immediately before the reorganization X total net cost amount of property retained by Transferor / total net cost amount of all property of Transferor immediately before the reorganization. ...

The ULC-LLC Loans, the LLC-FA Subco Loans, the LLLP-ULC Loan and the Term Advances (owing by LLLP) will be settled in accordance with their terms – with the accrued interest owing by FA Opco, FA Subco and LLLP being paid. ... Income derived by LLC from the interest payments [on the LLC-FA Subco Loans] will be included in computing the income from an active business of LLC, for its taxation year in which the payment will be received, in accordance with the following provisions: (1) subclause 95(2)(a)(ii)(B)(I) to the extent of the portion of the interest paid or payable by FA Subco in respect of the portion of the proceeds from LLC – FA Subco Loans that were used by FA Subco in the relevant period to earn income from the [FA Subco FA Opco Loans], and (2) clause 95(2)(a)(ii)(D) to the extent of the portion of the interest paid or payable by FA Subco in respect of the portion of the proceeds from LLC – FA Subco Loans that were used by FA Subco in the relevant period to subscribed for additional common shares of FA Opco… provided that the FA Subco common shares continue to be Excluded Property and FA Subco and FA Opco continue to meet the conditions in that clause with respect to their residence and being subject to taxation in the Foreign Country, and such interest will be included in computing the "earnings" from an active business of LLC and its "exempt earnings" in accordance with the definitions in Part LIX…. ...

The ULC-LLC Loans, the LLC-FA Subco Loans, the LLLP-ULC Loan and the Term Advances (owing by LLLP) will be settled in accordance with their terms – with the accrued interest owing by FA Opco, FA Subco and LLLP being paid. ... Income derived by LLC from the interest payments [on the LLC-FA Subco Loans] will be included in computing the income from an active business of LLC, for its taxation year in which the payment will be received, in accordance with the following provisions: (1) subclause 95(2)(a)(ii)(B)(I) to the extent of the portion of the interest paid or payable by FA Subco in respect of the portion of the proceeds from LLC – FA Subco Loans that were used by FA Subco in the relevant period to earn income from the [FA Subco FA Opco Loans], and (2) clause 95(2)(a)(ii)(D) to the extent of the portion of the interest paid or payable by FA Subco in respect of the portion of the proceeds from LLC – FA Subco Loans that were used by FA Subco in the relevant period to subscribed for additional common shares of FA Opco… provided that the FA Subco common shares continue to be Excluded Property and FA Subco and FA Opco continue to meet the conditions in that clause with respect to their residence and being subject to taxation in the Foreign Country, and such interest will be included in computing the "earnings" from an active business of LLC and its "exempt earnings" in accordance with the definitions in Part LIX…. ...

"Beneficiary" means any person designated by a Participant by written instrument filed with the Corporation to receive any amount, securities or property payable under the Plan in the event of a Participant's death or, failing any such effective designation, the Participant's estate; … DSU Account shall be redeemed and paid by the Participant's Employer to the Participant or the Participant's Beneficiary, as applicable. ...

14 February 2012 Ruling Case No. 99181 [non-exclusive information use rights]-- summary under Section 10.1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part V- Section 10.1 non-exclusive information use rights A Canadian company which is a registrant (the "Resident Supplier") enters into an agreement with a non-registered non-resident company to supply it "with the non-exclusive use rights to information belonging to the Resident Supplier for an up front payment of CD$[…] and contingent payments of CD$[…] in each of the succeeding […] years. ...

. … In addition, an instructor who provides private lessons to one individual at a time with a customized program for each client is normally not regarded as a school. ...