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Accordingly … Opco is not a bankrupt corporation for the purposes of subsection 128(1). ...

After finding that s. 115(2)(c) did not apply to deem the employment after the departure to be exercised in Canada, CRA stated: Consequently … if the non-resident person does not perform any of the employee’s employment duties in Canada, there would be no withholding tax with respect to the federal tax. ...

4 December 2007 Internal T.I. 2007-0237461I7 F- Définition d'activité de construction-- summary under Subsection 238(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 238- Subsection 238(2) construction activities included cable installation, maintenance and upgrading/primarily means over 50% The taxpayer, which had queried whether it was required to file T5018 slips for payments made to subcontractors, was engaged in the installation of cabling, both public and residential lines – and also was involved in the construction of overhead and underground cables, the installation of equipment, the maintenance and renovation of networks, the interior and exterior pre-wiring of buildings and the installation and servicing of certain products. ...

(c)(i) of the definition of "qualified small business corporation share," CRA stated: [P]ursuant to subparagraph 110.6(1)(c)(i) of the definition of QSBC, [CRA] is of the view that the phrase "attributable to assets used principally in an active business carried on … by the corporation" should be interpreted to refer to the fair market value of assets owned by the corporation. ...

2016 Ruling 2016-0652041R3- Loss consolidation arrangement-- summary under Paragraph 55(2.1)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) s. 55(2) ruling re dividends on preferred shares used in loss shift Respecting a triangular loss-shifting arrangement for the shift of non-capital losses by Parentco to its wholly-owned Profitco (with Profitco using the proceeds of an interest-bearing loan from Parentco to subscribed for preferred shares of a Newco subsidiary of Parentco, with dividends on such shares being funded with contributions of capital from Parentco), CRA ruled that s. 55(2) would not apply to the dividends paid by Newco to Profitco to fund the interest on the loan by Parentco to Profitco, based on a representation that: The only purpose of both the payment and the receipt of the dividends on Newco’s Preferred Shares … is to provide a reasonable return on the Newco Preferred Shares issued by Newco to Profitco. ...

In finding that this was a prescribed prize, the Directorate stated: [T]he prize of excellence … was publicly recognized. ...

. … [T]here is no jurisprudence dealing with filling the hole in a situation such as the one under review. ...

. … [W]e cannot conclude that he is entitled to perform most or all of the duties of a minister, including, inter alia, administering most of the sacraments of the Roman Catholic Church. ...

. … [W]e cannot conclude that he is entitled to perform most or all of the duties of a minister, including, inter alia, administering most of the sacraments of the Roman Catholic Church. ...

. … [T]he term transport business does not include a transportation service that is incidental, where the services offered are offered as part of a whole. ...