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CRA stated: Provided there is clear evidence, at the time of the disposition of the excluded property, that arrangements are being made for the repayment (with due dispatch) of the "related debt"...the fact that the actual repayment of the debt occurs after the disposition of the excluded property would not, in and by itself, result in the debt not being considered "... related at all times... ". However if it was determined that other factors (such as cash flow problems, or unfavourable prevailing interest or exchange rates) contributed to the delay in repayment, it is likely that the provisions of paragraph 95(2)(i) would not apply on the repayment of the debt. ...

In finding that the individual thereby realized a s. 7 taxable benefit that was computed in the usual manner notwithstanding that a portion of that benefit had accrued prior to his immigration, CRA noted that s. 7 benefits were excluded under s. 128.1(1)(b)(iv) and s. 128.1(10) – excluded right or interest – (c). ...

16 December 2008 Internal T.I. 2008-0300361I7 F- Déductibilité de l'impôt minimum sur les sociétés-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose Ontario CMT is non-deductible In finding that the Ontario corporate minimum tax ("CMT") provided for in ss. 57.1 to 57.12 of the Corporations Tax Act was not deductible in computing income, the Directorate first noted that the “CMT is therefore a calculation of tax based on a corporation's income, with adjustments, appearing in its financial statements,” and after quoting the statement in Roenisch, 1 DTC 199, that “such payment of taxes … made to the province … is not so made to earn the income, it is paid because there is an income showing gain and profit,” the Directorate stated: Since the CMT is a tax effectively calculated on income, it is therefore not deductible by virtue of paragraph 18(1)(a). ...

23 November 2004 External T.I. 2004-0094101E5 F- IT-474R Administrative Relief-- summary under Subsection 20(24) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(24) amalgamated corporation can make s. 20(24) election The taxpayer referenced the statement in IT-474R, para. 10 that “[w]here the provisions of paragraph 87(2)(a) produce unintended consequences … the Corporate Rulings Directorate … is prepared on a case by case basis to consider whether relief is appropriate.” ...

During the review period, the CRA continues to administer employee discounts on merchandise in accordance with the administrative policy outlined in Guide T4130, Employers Guide – Taxable Benefits and Allowances …. ...

In finding that the Corporation was not entitled to a deduction in 2001 for the CADD amounts pursuant to s. 20(1)(vv), and before going on to find that s. 18(1)(e) denied a s. 9 deduction, the Directorate stated: Paragraph 20(1)(vv) … allows for the deduction of such duties as long as they are paid. … In the current context, [“paid’] … means "to discharge a debt". ... Consequently, we are of the view that the provisions of paragraph 20(1)(vv) do not apply …. ...

A under subparagraph (e)(i) of … “excluded amount” …. CRA then addressed an example where, in Year 1, Opco pays a $1M dividend to Investco and Investco then invests that dividend in shares of publicly-traded corporations. ...

“However, no property will be acquired by a person described in subclause 88(1)c)(vi)(B)(I), (II) or (III) in the course of the following series: the transactions or events which include the amalgamation …. or winding-up ….” ...

(This step will “ensure that US Parent’s status as a holding company for … net worth … tax is not jeopardized by the completion of the Proposed Transactions. ...

. … In the example submitted, the CRA would not consider a Class A share … to be identical to a Class B share …. ...