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Aco then redeems the $100,000 of preferred shares (giving rise to a deemed dividend to Bco of that amount – which is not subject to s. 55(2) as Bco had full ACB in those shares), and BCo uses the redemption proceeds to discharge the note owing to A. ...

. … It does not mean that the place of activities must exist for a long time or be located in a durable building; for instance, a temporary field office on a construction site could be a fixed place of activities. ...

. … It does not mean that the place of activities must exist for a long time or be located in a durable building; for instance, a temporary field office on a construction site could be a fixed place of activities. ...

1 December 2009 External T.I. 2009-0307821E5- TFSA Contributions- Options and Warrants-- summary under Paragraph 7(1)(c) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(c) contribution to TFSA – recognition deferred until exercise by TFSA What are the tax consequences of an employee stock option being contributed to a TFSA? ...

The parent of Holdco (“Canco”) then transfers shares of directly-held foreign affiliates (“FAs”) to Holdco in consideration for Holdco shares, and Holdco then transfers such FA shares to DC (and to Newco under s. 85(1)) in consideration for an increase to its membership interest in DC by an amount equal to the FMV of such transferred shares (and for the issuance of Newco shares – with Newco then dropping down its FA shares to DC in consideration for a correlative increase in its membership interest). ...

After noting that Cummings found “that the payment of fees to a real estate broker for finding tenants and entering into new leases is generally a current expense” and that Canderel found that “in order to obtain a better or a more accurate picture of the landlord's profit, the lease incentive payments were current expenses that were deductible in the year, and which were not subject to the matching principle because they brought significant and numerous benefits immediately in the year of payment,” CRA stated: [A]ssuming, of course, that this remuneration represents an expense of a current nature … the remuneration would be deductible in the years in which it is paid. ...

CRA responded: … ITR subsection 2601(1) provides that if an individual resides in a particular province on the last day of a taxation year and has no income for the taxation year from a business with a permanent establishment outside the province, the individual’s income earned in the taxation year in the particular province is the individual’s income for the taxation year. ...

. … 460354 Ontario Inc. (92 DTC 6534) and Hadi Saraf… (94 DTC 6229), …[involving] the Ontario Business Corporations Act, held that an assessment is an administrative action and therefore a dissolved corporation may be assessed or reassessed, provided the relevant time limit has not expired. ...

. … [T]wo partnerships may achieve a certain form of merger, if each of them distributes all of its property to its partners, in accordance with paragraph 98(3), and if each partner subsequently invests the property so received in a new partnership in accordance with subsection 97(2). ...

In this regard, CRA quoted a judicial statement that "the courts have concluded that the concept of loan or advance is related to the existence of a payment of money between two parties and to the presence of that relationship of lender / borrower," and then stated: [T]he contractual relationship between CFA 1 and CFA 2 with respect to the Debt establishes a creditor/debtor relationship and not a lender/borrower relationship. ...