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3 August 2018 Internal T.I. 2018-0755351I7- Trust claiming CG reserve-- summary under Subsection 104(21.2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(21.2) flow-through of s. 110.6 treatment respecting distributed capital gains reserve In response to questions as to whether the lifetime capital gains exemption (LCGE) was available where a personal trust claimed a capital gains reserve and distributed it, the Directorate stated: [The reserve amount … is included in calculating its capital gain in the following year. ...

In this regard, we note that in Advance Income Tax Ruling # 2006-0187681R3, issued in 2007, the Rulings Directorate concluded that the Sameignarfelag discussed in that ruling would qualify as a partnership for purposes of the Act. ...

28 September 2018 External T.I. 2018-0779261E5- Investment management fees-- summary under Subparagraph (b)(i) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (b)- Subparagraph (b)(i) proposal to impose advantage tax, where RRSP or TFSA fees are paid by the annuitant or holder, pending a Finance review In 29 November 2016 CTF Roundtable Q. 5, 2016-0670801C6, CRA indicated that it now considered the payment of fees for investment management of an RRSP, RRIF or TFSA by the plan annuitant or holder typically will be considered to be an “advantage” giving rise to tax under s. 207.05(1) equal to 100% of the fee amount (noting inter alia under the hypothetical arm’s length test in s. 207.01(1) – advantage- (b)(i) that it would not be “commercially reasonable for an arm’s length party to gratuitously pay the expenses of another party”) but that to give the investment industry time to make the required system changes, it would defer applying this new position until January 1, 2018. 2017-0722391E5 announced a one-year extension to January 1, 2019. ...

. … As such, in the example provided, ACo would be first subject to the passive income reduction in its first taxation year beginning after 2018 (i.e., ACo’s taxation year ending December 31, 2019). ...

. … In the particular situation, Partnership had a taxation year that commenced on January 1, X9 and ended immediately before the time immediately prior to the time it ceased to exist. ...

. … [I]t is our view that the requirements of paragraph 108(2)(a) have been satisfied. ...

18 June 1998 External T.I. 9805705- ASSOCIATED CORPORATIONS-- summary under Subsection 256(1.4) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1.4) In indicating that s. 256(1.4)(b) could apply where pursuant to a unanimous shareholders agreement a corporation would automatically acquire the shares of a shareholder where there is a change in control of the shareholder, a receiver of the shareholder was appointed, the shareholder breached specified covenants in the agreement, the shareholder encumbered its shares or they were attached, Revenue Canada stated "... ...

[stated]: "...., the Department is prepared to make an exception in cases where a corporation does not exercise significant influence, if it can be clearly demonstrated (emphasis added) that the income of the other corporation contributed to the unrealized gain on the shares. ...

Thus, in our view, term deposits and guaranteed investment certificates issued by XXXXXXXXXX to non-residents would constitute similar obligations for the purposes of subclause 212(1)(b)(ii)(C)(II) …. ...

The correspondent: noted that the "acquisition" or "sale of stock index futures is similar in nature to a transaction in "naked options" in that no property is actually purchased or sold and, further, that paragraph 25 of … IT-479R states that, while transactions in "naked options" are normally on income account, the Department will accept the reporting of gains or losses on capital account provided this practice is followed consistently from year to year. ...