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. … Thus, an RCA trust will be required to include in computing its refundable tax at the end of a taxation year the amount of interest required to be included in computing income from property pursuant to subsections 12(3) and 12(4) and paragraph 12(1)(c) for the year or for a preceding taxation year. ...

In finding that the taxpayer would not be required to pay interest pursuant to s. 161(1) notwithstanding s. 161(7)(a)(iv), the Directorate stated: 9733167 … confirmed that interest should not be calculated by pursuant to subsection 161(1) or (2) where a deduction is substituted by a carryback of losses, tax credits or other amounts from subsequent years and this does not change the original assessment. ...

. … [T]he Proposal does not prevent Mr. A from selling his shares. Indeed, the Proposal is an agreement independent of the agreement to sell the Corporation’s shares and the sale of the shares must take place in order for the creditor payment clause of the Proposal to apply. ...

Furthermore, we are of the view that the French and English versions of paragraphs 256(3)(a) and 256(6)(a) have the same meaning and that the expression "under which" used in the English version does not allow for a broader interpretation of the verb "stipuler" used in the French version …. ...

" In indicating that an investment allowance might not be allowed for such a policy, CRA stated: [T]he only assets issued by a corporation that is a financial institution that qualify for the investment allowance … are a share of the financial institution or a long-term debt. ...

. … [T]he fees paid by the corporation for the principal shareholder should be included in the principal shareholder's income pursuant to subsection 15(1). ...

Second, a corporation that receives an eligible dividend from a payer corporation is subject to Part IV tax whether or not the payer corporation receives the DR – so that if CCRA allowed a corporation to waive a DR, this would have no effect on the Part IV tax payable by the other corporation. ...

A, who had held all the shares of HoldcoA on April 26, 1995 at which time HoldcoA held a policy on the life of A whose purpose was to fund the redemption of such shares, transferred those shares to another wholly-owned corporation (HoldcoB – all of whose shares being Class B shares were held by him) under s. 85(1) in consideration for 100 "new Class B shares" of HoldcoB. ...

In this regard, the Directorate stated: [T]he provisions of paragraph 40(2)(g)(ii), that deem a loss on the disposition of certain debt obligations to be nil, do not apply since the … debt obligation was interest-bearing, as the taxpayer was subrogated by the financial institution as to the interest-bearing mortgage ...

. … [T]he provisions of section 22 of the Regulation will not, in and of themselves, prevent the deduction of interest on money borrowed to acquire common shares of a QBIC if there is otherwise a reasonable expectation, at the time the shares are acquired, that the holder of the common shares will receive dividends. ...