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The Queen, it is the position of our Directorate that a flexible approach to tracing funds is to be used in the context of the application of subsection 84(2). […] It should be noted that the Federal Court of Appeal in MacDonald did not consider the brother-in-law to be an accommodation party to the transaction, as in RMM, in concluding that s. 84(2) applied. ... As stated in MacDonald [at para. 27, quoting RMM], the " words ‘distributed or otherwise appropriated in any manner whatever on the winding-up, discontinuance or reorganization of its business’ are words of the widest import, and cover a large variety of ways in which corporate funds can end up in a shareholder’s hands.” ... This was a well-considered scheme adopted on the advice of professional advisers after other means of extraction of the undistributed income (…) However, it is the CRA's view that the strict and literal approach to the interpretation of subsection 84(2) adopted by the Federal Court of Appeal in Vaillancourt-Tremblay has clearly been rejected by that same court in MacDonald. ...

Income Tax Technical News No. 19, 16 June 2000-- summary under Paragraph 110(1)(d) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110- Subsection 110(1)- Paragraph 110(1)(d) "... ...

IT-291R3 "Transfer of Property to a Corporation under Subsection 85(1)"-- summary under Paragraph 85(1)(b) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(b) allocation of assumed debt amongst transferred properties 17 … Paragraph 85(1)(b), however, will not apply where the fair market value of the non-share consideration given (including the assumption of debt by the transferee) is allocated among several properties transferred and retained by the transferee and the amount allocated to each asset is not greater than the agreed amount in respect of each asset. ...

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. … Mobile electronic devices, such as mobile phones, are considered to be ordinarily situated in BC if they are assigned a BC area code. ...

. … We will apply the Court’s decision in Miedzi Copper [and Stantec] where the situation has the same facts as that case. ...

. … 6. While cases may arise where interest is computed retroactively, no penalty will be imposed retroactively as a result of an amendment to Part IX of the Act. ...

. … An independent contractor for services must also be distinguished from an agent. ...

FAQ- Deferral of GST/HST Tax Remittances: CRA and COVID-19 20 April 2020 CRA Webpage (as amended on June 29, 2020)-- summary under Section 280.1 Summary Under Tax Topics- Excise Tax Act- Section 280.1 no penalties for late-filing GST/HST returns on June 30, 2020 CRA announced that although “The deadline for businesses to file their [GST/HST] returns is unchanged … the CRA won’t impose penalties where a return is filed late provided that it is filed by June 30th.” ...

Specified person – In addition to giving facts and reasons for objecting, a specified person has to describe each issue and specify the relief the person wants for each one. ...