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CRA indicated that the company providing the trips should issue T4A slips to the individual proprietor, or to the individual receiving the trip as a benefit qua employee of the individual’s personal corporation – whereas no T4A slip is required if the trip was received as a benefit qua shareholder of the personal corporation (a distinction which in practice would be difficult or impossible for the trip provider to apply). ...

10 October 2008 Roundtable, 2008-0285471C6 F- Fiducie étrangère exempte- fiducie admissible-- summary under Fixed Interest Summary Under Tax Topics- Income Tax Act- Section 94- Subsection 94(1)- Fixed Interest discretion as to payment timing is acceptable – but discretion in choice of record dates could affect beneficiaries’ respective shares Where the trustee of an investment trust has discretion as to the timing of distributions of income or capital without any discretion as to the share of income or capital distributable to each beneficiary, would such discretion result in the trust not being eligible under para. ...

. … [I]n order to determine whether B is related to each member of the group that controls AB Inc., B, as owner of shares of the capital stock of B Inc. and AB Inc., would be deemed, as a shareholder of B Inc., to be related to himself as a shareholder of AB Inc. by virtue of subsection 256(1.5). ...

[E]ven if the "deed of correction" of the Contract …were to be entered into … CRA could not take it into account for the purposes of determining the tax consequences of the transfer of the Immovable. ...

In this regard, the T2 Corporation Income Tax Guide … states that the Part I tax payable for the year is the basic Part I tax plus the amount of surtax, the amount of recapture of the investment tax credit, and the refundable tax on the Canadian-controlled private corporation’s investment income, minus any allowable deductions and credits, including the federal tax credit for forestry operations. ...

. … We have brought this situation to the attention of the Department of Finance. ...

. … [T]he provisions in paragraph 147(2)(k) and subsection 147(19) apply even if the members are employees when withdrawing or transferring funds from a DPSP. ...

. … [However] in the hypothetical situation described above, the individual could benefit from a refund of overpaid instalments of $10,000 for the individual’s 2002 taxation year. ...

. … In this respect, the provision of sufficient security does not constitute a payment. ...

In light of the facts … throughout the 24-month period preceding the disposition of the ABC Inc. shares by X and Y, they were not owned by anyone other than a person or corporation related to them. ...