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After noting that the “rules in section 306 … apply on a policy-by-policy basis and require actuarial calculations and information that only the issuing insurer will possess,” CRA responded: A life insurance policy issued by a non-resident insurer is not specifically precluded from qualifying as an "exempt policy" and thus, such a policy could qualify provided the criteria in section 306 of the Regulations are satisfied. ...

. … Under paragraph 148(7)(b), Employee B will be deemed to have acquired the policy at a cost of $50,000 (which is the amount determined under paragraph 148(7)(a)). ...

This created a problem for its ability to elect under (c)(i) of the definition of “public corporation” in s. 89(1) to cease to be a public corporation- which was that it did not literally satisfy the requirement in Reg. 4800(2)(a)(i) that “insiders of the corporation shall hold more than 90 per cent of the issued and outstanding shares of each class … that was, at any time after the corporation last became a public corporation, listed on aa designated stock exchange in Canada [or of designated surrogate qualified-for-distribution shares under Reg. 4800(2)(a)(ii)].” ...

. … [T]he reassessments would be attributable to FAPI arising directly from the contribution by the Taxpayer of the Marketable Securities to ForeignCo which, in our view, would be a "transaction" between Holdco and ForeignCo referred to in subparagraph 152(4)(b)(iii) that it would be reasonable to consider as relating to the reassessments for purposes of subparagraph 152(4.01)(b)(iii). ...

B's child under s. 252(1)(c) – and they would not otherwise be related. ...

CRA responded: [G]enerally … “benefits” are received qua shareholder where that person can significantly influence the corporation’s business policy. ...

In accordance with Abrahamson … the fact that the original source of funds in a foreign individual retirement plan was a pension plan is not relevant. ...

., the work and energy that the individual devotes to the business and the nature of the business itself – so that, the more an individual is involved in the management and/or current activities of the business, the more likely it is that the individual will be considered to be actively engaged. ...

7 June 2019 STEP Roundtable Q. 14, 2019-0798511C6- TOSI and PBE-- summary under Subparagraph (a)(i) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Split Income- Paragraph (a)- Subparagraph (a)(i) subjecting dividend income paid to a preferred beneficiary to TOSI accords with tax policy – but the designation can be readily avoided The Summary portion of 2018-0759521E5 indicated that if a s. 104(19) designation is made respecting a preferred beneficiary income amount resulting from an election under s. 104(14), the amount would be includable in split income under para. ...

Thus, the home acquired in July 2019 could, if all the other conditions … are otherwise satisfied, qualify as a "qualifying home" for the purposes of the FHBTC. ...