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In finding that the annual dividends were not subject to Part IV tax because Opco was connected to Holdco under s. 186(4)(a), CRA stated: … Opco is controlled (otherwise than by means of a right described in paragraph 251(5)(b)) by Holdco at that time, by virtue of 186(2). ...

Turning to the deferred share issuance consideration, the Directorate noted that the shares’ market price could “fluctuate greatly,” and indicated that the TSO accordingly might: conclude that such portion of the proceeds of disposition for the Mining Properties by the Vendor is not determinable prior to the date of issuance of the shares by the Purchaser and that such portion of the proceeds of disposition would be recognized for tax purposes at the times of their issuance …. ...

The CRA is, however, prepared to consider that issue as part of an advance income tax rulings request …. ...

Since subsection 7(1.3) applies for the purposes of subdivision c of Division B of Part I …, if the disposed of security is not a [s. 7(1.1)] deferred security, subsection 47(1) applies to determine the ACB subject to any applicable adjustments pursuant to paragraph 53(1)(j). ...

. … [T]he fact that there is an issuance of shares of the capital stock of a transferee corporation, after the distribution of the property of the distributing corporation has been completed, would not be relevant for the purposes of the application of the definition of "permitted exchange" in subsection 55(1). ...

Finally … to the extent that the control of the transferee corporation was not acquired by the family trust, subparagraph 55(3.1)(b)(ii) would also not be applicable. ...

. … [T]he taxpayer could claim the METC for the medical expenses incurred in 2007, 2008 and 2009 in that the taxpayer no longer has the right to be reimbursed for these expenses as part of the group drug insurance plan. ...

After noting that “subparagraph 110(1)(d.01)(iii) provides that the gift must be made in the year and on or before the day that is 30 days after the day on which the taxpayer acquired the security” and that “A taxpayer who wishes to benefit from the deduction provided in paragraph 110(1)(d.1) must inter alia hold the securities … for a minimum period of two years,” CRA stated: [A] taxpayer who is only eligible for the deduction under paragraph 110(1)(d.1) will not be eligible for the deduction listed in paragraph 110(1)(d.01) because it will be impossible for the taxpayer to satisfy both the requirement of subparagraph 110(1)(d.01)(iii) and that of subparagraph 110(1)(d.1)(ii). ...

. … [T]he use of a motor vehicle for personal purposes generally includes travel between a taxpayer's home and the taxpayer’s place of business, unless it can be shown that the taxpayer’s principal place of business is the taxpayer’s home. ...

A further situation discussed was where a trust is established by the employer to acquire and hold shares of the corporation for employees, but allocations among the employees are entirely at the discretion of the trustees – so that CRA would consider that there is no agreement to acquire the shares until such discretion is exercised. ...