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In rejecting this submission, CRA stated: Assuming that the adjusted cost base of the exchanged common shares was nominal … the value of each class of shares … received on the exchange … would generally represent both a share of income earned or realized by Opco and a share of income not earned or realized …. Accordingly … the new shares issued by Opco would generally share the safe income on hand attributable to the old common shares on the basis of the gain inherent in each of them at the time of the exchange. The safe income on hand of Opco attributable to the former common shares would therefore … generally be allocated based on the proportion that the unrealized gain inherent in the Preferred Shares at the time of the exchange bears to the total unrealized gain, at the time of the exchange, inherent in the shares received on such exchange. ...

Regarding whether this generated a taxable benefit under s. 6(1)(a), CCRA stated: [E]xpenses incurred by the employee to improve the employee’s housing unit that are not within the scope of those normally assumed or reimbursed by a landlord should not … reduce the value of the benefit …. However … where the expenses incurred by the employee are expenses that are normally borne by a landlord, the amount of this benefit could be reduced by a reasonable amount, which represents the disbursements made by the employee for work related to the employee’s housing unit that primarily benefits the employer/landlord. … Furthermore, we disagree that the value of the benefit computed for the purposes of paragraph 6(1)(a) should be reduced to take into account the time spent by the employee in carrying out the renovation work on the employee’s housing unit. ...

Based on this information, we are of the view that those plans generally satisfy the definition of the term "forest management plan" as currently defined in the Explanatory Notes …. … [I]t is not the forest engineer's report setting out the development expenditures eligible for the property tax refund that constitutes a "forest management plan" for the purposes of subsections 70(9) and 73(3), but rather the certified forest management plan that the taxpayer filed to obtain forest producer status under section 120 of the Forest Act. ...

8 October 2010 Roundtable, 2010-0373241C6 F- Acquisition of Control-- summary under Subsection 256(6.1) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(6.1) purpose is to take into account simultaneous control at the various levels In the course of a non-committal response as to whether there is an acquisition of control of a public company when its shareholders exchange most of their shares for shares of a Newco, CRA responded: [S.] 256(6.1) … is the legislative response to … Parthenon Investments …. ...

17 July 2007 External T.I. 2007-0220121E5 F- Lac artificiel- catégorie d'amortissement-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 6- Paragraph (e) artificial lake qualifies as a “water storage tank’ Before finding that the costs of creating an artificial lake to be used for a fishing resort should be included in Class 6, CRA noted: … Oriole Park Fairways … 56 DTC 537 … relied on the ordinary meaning of the words "water storage tank"- which includes “a pool or lake, or an artificial reservoir”- to conclude that ponds on a golf course should be capitalized in Class 6 Words and Phrases water storage tank ...

18 May 2000 Internal T.I. 2000-0006037 F- FRAIS D'ACQUISITION-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing commissions directly related to the acquisition of a life insurance policy are generally deductible in the year incurred CCRA indicated that “the matching principle mentioned in … IT-417R2 as well as the Agency's comments on the Canderel and Toronto College decisions set out in Income Tax Technical News No. 16 [and] … F9913160 … do not apply to acquisition expenses incurred by an insurer” (i.e., life insurance policy acquisition expenses, including commissions directly related to the acquisition of the policy) but indicated that generally, those expenses are deductible in the year in which they are incurred. ...

9 July 2024 Internal T.I. 2023-0976691I7- Film Tax Credit and Alter Ego Trust-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership the property of an alter ego trust “belonged” to its sole trustee and life beneficiary rather than to the trust In order for a fee paid to a corporation for the executive producer servicers of an individual employed by the corporation to qualify for the B.C. production services tax credit, there was a requirement (essentially copied from ITA s. 125.4(1) – labour expenditure – (b)(iii) and s. 125.5(1) – Canadian labour expenditure- (b)(iii)) that the shares of the corporation “belong” to a BC-based individual – whereas, here, the shares were held by the individual in his capacity of trustee of an alter ego trust which had been settled by him (to avoid B.C. probate duties) and of which he was the life beneficiary. In finding that this shareholding satisfied the above “belong to” test, rather than the shares belonging to the trust, the Directorate stated: [T]he shares … belong to [the individual] and not the Trust for purposes of the tax credit. ... {Here] … [the individual] has legal ownership of the shares in [the individual’s] role as trustee, and beneficial ownership of the shares as the sole beneficiary who is entitled to the income on the shares while [the individual] is alive …. ...

The percentage of relevant Canadian property for TCPCo is 100% (equal to $2 M / $2 M x 100). … [T]he percentage of relevant Canadian property for AusCo is 0% (equal to $0 / $10 M x 100). ... The proportionate value approach as described in 2015-0624511I7 can be summarized as follows: the percentage of relevant Canadian property of a particular subsidiary entity should be multiplied by the FMV of the shares of that entity; and the product resulting from above is the prorated FMV of the shares of the particular subsidiary entity which represents the FMV of a relevant Canadian property asset indirectly held by the parent. … [T]his would result in BVCo having a percentage of relevant Canadian property of 67% = $1 M / $1.5 M. Since more than 50% of the FMV of BVCo’s shares is derived from real or immovable property situated in Canada, the shares of BVCo are TCP …. ...

Regarding a bank loan received by Dco whose proceeds are used by it to make an interest-free loan to the LPs, CRA stated: [T]he comments in … S3-F6-C1, [paras. 1.54, 1.55] could apply in the partnership context …. ... Regarding the bank loan instead being made to Aco which uses the proceeds to directly or indirectly make an interest-free loan to the LPs (e.g., making such loan to Dco which, in turn, makes interest-free loans to the LPs, or to Bco, with back-to-back interest free loans made all the way down the stack), CRA stated: [I]n light of … Canadian Helicopters, the fact that the taxpayer's income is derived from dividends from stacked corporations should not be a factor that … prevents a taxpayer from relying on the direct use of borrowed funds exception to make an interest-free loan. [I]t would be necessary to assess … whether the interest-free loans made by Aco to the LP, Bco or Dco … affect Aco's ability to earn income. ...

X …. The Residence would therefore have been disposed of by [them to] Mrs. X …. Regarding the verbal agreement … it is up to the taxpayer to demonstrate the existence of such an agreement whose effect is to transfer the ownership of the Residence at a particular time other than on XXXXXXXXXX. If the taxpayers can provide evidence to you of that verbal agreement, you should consult … Legal Services …. ...