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In addition …, it would be appropriate to consider that the same conclusion would apply regardless of whether or not the transactions are being undertaken to avoid the 21-year deemed disposition rule in subsection 104(4). ...

. … [W]here a particular class of member is determined, the deduction for a taxation year under subsection 137(2) of the Act by a credit union for bonus interest payments or payments pursuant to allocations in proportion to borrowing, as the case may be, requires such bonus interest payments or allocations in proportion to borrowing to be credited to all taxpayers who were members of that particular class in the year. ...

If the PF is an EBP, the amounts received therefrom would be taxable under s. 6(1)(g), subject to certain exceptions including that in 6(1)(g)(iii) regarding pension benefits received out of the plan that are attributable to services rendered by a person in a period throughout which the person was not resident in Canada – in which event, they would be fully taxable under s. 56(1)(a)(i) “even if the employee’s contributions to the pension plan were not deductible under the Act and even if the pension benefits are tax-free in whole or in part in a foreign jurisdiction.” ...

CRA further announced in 2020-0846751E5: In these extraordinary [COVID] circumstances, a HCSA that qualifies as a PHSP and which has unused credits expiring between March 15 and December 31, 2020, could temporarily permit the carry forward of those unused credits for a … period of up to six months [which] would generally be considered reasonable and would not, in and of itself, disqualify the HCSA from being a PHSP. ...

After noting that this definition can include an amount required to be paid under a net lease to a third party, such as an energy distributor, CRA indicated that “where a lease states only that a tenant is responsible for a certain cost … this would generally not constitute a qualifying rent expense.” ...

After citing Transalta for the proposition that “a discretionary arrangement that does not give employees the right to require that equity-based compensation be paid in the form of shares rather than cash is not an agreement to sell or issue shares for purposes of section 7,” it stated: … USCo can unilaterally decide to settle RSUs payable to CanCo employees in the form of cash rather than issuing Shares. ...

(a)(ii) of the ERDTOH definition – whereas para. (b) of the NERDTOH definition includes all other Part IV taxes payable by the corporation on dividends from a connected corporation, the Directorate stated: A corporation will not have transitioned to the ERDTOH and NERDTOH regime in its taxation year that begins before 2019 and cannot receive a refund from its ERDTOH account with respect to dividends paid in that taxation year. ...

Here, as the insurance share was retractable by the holder immediately before the death for the CSV, it would not be unreasonable to allocate the policy CSV to the insurance shares – so that the value of the common shares would not take the policy CSV into account. ...

(g)(ii) (where the beneficiary is 24 years before the particular year), CRA stated: In a situation where the individual has not assumed any risk, whether an arm’s length rate of interest charged is a reasonable return is a mixed question of fact and law …. ...

(g)(ii): In a situation where the individual has not assumed any risk, whether an arm’s length rate of interest charged is a reasonable return is a mixed question of fact and law …. ...