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. – which, in turn, could engage s. 74.1(1) where the subscriber was X’s spouse. ...

., by X rather than Opco) where CRA would apply s. 69(1)(b) and Kieboom on the basis that X had disposed of an interest in Opco to the Class B share subscriber for the FMV of that interest – which, in turn, could engage s. 74.1(1) where the subscriber was X’s spouse. ...

CRA then stated: [I]f X disposed of any right or interest in Opco to X's spouse … we could also argue that the attribution rules in subsection 74.1(1) would apply to reallocate to X any dividends paid on the Class B shares held by X's spouse. ...

. … Since Mr. A and Ms. B lived in separate self-contained domestic establishments during the period of the year in which they lived apart, the concept of the same "self-contained domestic establishment" in 118(4)(b) does not restrict the right of Mr. ...

. … Subparagraph (e)(ii) of the definition of automobile refers to pick-up trucks and/or vans the use of which, in the taxation year in which they are acquired or leased, are all or substantially all for the transportation of goods, equipment or passengers in the course of gaining or producing income. ...

. … …[T]o the extent that the CFVP was the only depreciable property included in Class 10, the change in use of the CFVP results in no property being included in Class 10. ...

30 September 2010 Internal T.I. 2010-0373901I7 F- Bigamie fiscale- transfert de biens au décès-- summary under Subparagraph 40(4)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(4)- Paragraph 40(4)(b)- Subparagraph 40(4)(b)(i) application of s. 40(4)(b)(i) by both surviving spouse re House A and surviving common-law partner re House B – but not for overlapping years The taxpayer lived with his spouse in Immovables A, but thereafter commenced to live separate and apart from her, but did not divorce from her, and instead lived in a conjugal relationship with another (a common-law partner) in Immovable B until his death. ...

. … The following are some elements that may be considered by the CRA in determining the "normal rate of return" in a particular situation: The rate of return that the corporation could earn on the capital invested to acquire the property made available to its shareholder; The rate of interest on a loan that the shareholder would have received from a person with whom the shareholder deals at arm's length if the shareholder had borrowed personally to acquire the property made available to the shareholder. ...

. … [K]eeping in mind that what is being valued are conditions of a sale that are essential to the closing of the sale, the various elements that would have an impact on the income of the business sold must be evaluated in light of each individual situation. ...

After indicating that no reserve under s. 20(1)(m) was available, and confirming its position in IT-215R, para. 13, CRA stated: [A] clause permitting the return of goods not sold by customers is not a clause contemplated by paragraph 13 … where title passes to the purchaser upon delivery, well before the expiry of the time limit for the return of goods. ...