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. … [T]he Consent Fees are not management or administrative fees or charges…[and] are simply paid to retain the outstanding Credit Agreements. ...

If TP was unrelated to BP (meaning, broadly, that it had a minority interest), TP would be able under s. 80(9) to apply its deemed forgiven amount first against the ACB of its BP partnership interest that was disposed of on the winding-up and which was increased by the amount of the s. 80(13) income allocated to it – so that there would be a reduced, or no, amount of remaining s. 80(13) debt forgiveness income to be allocated by TP to its partners. ...

(Butterfly rulings typically have prorated UCC based on relative FMV – see e.g., 2014-0530961R3 and 2013-0498651R3). ...

. … As noted above, paragraph 38(a.1) will apply to deem a taxpayer’s taxable capital gain from a disposition of certain securities to be nil when the disposition is the making of a gift to a qualified donee. ...

Although the Taxpayer mostly had not deducted the amounts of the Interest Debt, in its return (apparently for Year X), the Taxpayer added such amounts to its non-capital losses at the beginning of the year – then in Year X+1, it deducted the forgiven amount, equalling the difference between the Interest Debt and the fair market value of its assets, from the balance of its non-capital losses. ...

CRA found that: [T]he Taxpayer’s right to reduce the Interest Debt … falls within the definition of a “right to reduce” in subsection 143.4(1) because it is reasonable to conclude, having regard to all the circumstances, that the right will become exercisable [i.e., that the conditions precedent would be thereafter satisfied]. ...

The TFSA contract requires the maintenance of an asset minimum (described as a “margin call provision … “in order to secure the loan”), i.e., so that the nephew cannot liquidate the TFSA unbeknownst to his uncle. ...

., the determination of whether the hypothetical particular person controls a corporation) for the purposes of paragraph (b) …. ...

CRA indicated: [W]here an employee works at a very great distance from the employer's place of business because of the requirements of the employment and not because of the personal choice made by the employee … the travel made by the employee between the employee’s place of work and the employer's place of business is travel made in the performance of the duties of the employee's office or employment. ...

In applying the surrogatum principle … the amount paid by the employer- to replace an amount that would not have been taxable- should not be taxable either. ...