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., its earnings as computed in accordance with the Country A income tax law – but that such adjustments were to be added to its earnings pursuant to Reg. 5907(2)(f). ...

CRA stated: [P]aragraph 94(2)(t) … applies to expunge the contribution after the time of the sale (i.e., from the time of the sale forward, the contribution is considered to have never occurred). ...

Treaty does not exempt shares deriving their value from Canadian oil and gas licences – even where the Canadian business is carried on “in” them If a U.K. resident disposes of shares of its Canadian subsidiary that derive the greater part of their value from rights related to an active oil and gas business, is the gain on the disposition exempted under para. 7? ...

., were subject to Part XIII tax under s. 212(1)(c) Similarly, “the transfer of the Trust’s assets to ULC … was for the benefit of Y and Z,” and s. 107(2.1) thereby applied to deem them to be disposed of for fair market value proceeds. ...

If Y and Z argued that s. 104(13) did not apply to them because no amount was payable to them in the year, CRA would apply s. 56(2) or (alternatively) s. 105(1) to include the dividend amounts in their income – but without any s. 104(6) deduction to the Trust. ...

IV(6) – and, similarly, LLC1 Itself would be considered to be deriving such income as a qualifying person if it had chosen to be treated as a corporation. ...

Before concluding that the interest was deductible under s. 20(1)(c)(ii), CRA referenced its position in Folio S3-F6-C1, para. 1.65 that “where a note is issued to purchase and cancel (or otherwise redeem) shares, interest expense may be deductible under subparagraph 20(1)(c)(ii),” and then stated: In a situation as such described above where there is a capitalization of a portion of a corporation's accumulated profits as stated capital of the preferred shares of the capital stock of the corporation, the CRA is of the view that the "capital" attributable to the preferred shares for the purpose of applying the "fill the hole" concept … generally corresponds to the paid-up capital of the shares. ...

Example 2 The fact that another entity owns the shared workspace is not important to the PE analysis – it is enough that the shared workspace is at the non-resident’s disposal. ...

XXIX A(3) – the US is engaged in the active conduct of a trade or business in the U.S.; the income is “derived from [Canada] in connection with, or incidental to, that trade or business (including any such income derived directly or indirectly by [the U.S. resident] through one or more other [Canadian residents] (the “connected test”); and the trade or business carried on in the U.S. is substantial in relation to the activity carried on in Canada giving rise to the income in respect of which treaty benefits are claimed- the connected test will not be satisfied. ...

CRA went on to state: [S]ubsection 6(14) … will not apply to such a plan to provide partial relief from the SDA rules for the main component of the award. ...