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A, the Directorate first noted that “For this provision to apply, the CRA must establish that the disposition of Class "F" shares of the capital stock of Opco … was part of the series of transactions or events in which Opco acquired the Class "AA" shares of its capital stock for consideration less than their fair market value,” and then stated: Although the “because of” or “in relation to” test [in Copthorne] of related transactions does not require a strong nexus, it does require more than a mere possibility or a connection with an extreme degree of remoteness. ...

If in the light of the damages for the building and the scale of the work to be effected it turns out that a new property is acquired by the taxpayer, section 44 can apply …. ...

However, in the same year, the equipment was also used for a number of months on other farmland owned by them in a non-qualifying region – and the equipment was not used at all in the winter months. ...

BCo will transfer its business on a rollover basis to a newly formed subsidiary limited partnership (New LP) in consideration for the assumption of liabilities and the issuance of Class A units; and ACo will fund New LP from time to time in consideration for the issuance of Class B units (which are not described in the letter to have much difference from the Class A units – including equal per-unit allocations of income or loss- except as described below) at a subscription price equal to a valuation of the NAV per Class A unit and Class B unit. ...

. … [T]he CRA has expanded its administrative position to the case where the property is utilized by a person who is related to a beneficiary as the property is, in that situation, a personal use property of the trust. ...

. … DC owns property ("Property1") which was rezoned…. From XX to XX, XX lots of Property1 have been severed and sold. ...

20 February 2014 External T.I. 2012-0460191E5- Permanent establishment in a province-- summary under Subsection 400(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 400- Subsection 400(2) general factors In the course of making general comments on the meaning of permanent establishment, CRA quoted from 2011-0395331I7, including the following: In … Dudney [2000] 2 CTC 56, a "fixed place of business" for the purpose of Article XIV of the Canada-U.S. ...

Furthermore, we generally consider the rates set out in section 7306 … to be reasonable for the purpose of calculating an allowance for the use of a motor vehicle referred to in paragraph 6(1)(b). ...

CRA stated: [T]he Technical Explanation to the 2007 Protocol states that subparagraph 2(a) provides a safe harbour rule that is applied on a calendar year basis …. ...

. … [A] distribution of income from a SIFT Trust is deemed to be a dividend pursuant to subsection 104(16)… and is similarly treated as a dividend for the purposes of the Treaty pursuant to the 2007 Protocol Annex B in regards to paragraph 3 of article X. ...