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However, planning contemplating the payment of an unreasonable amount of salary, particularly in circumstances similar to those described in [this] scenario … could be considered abusive,... ...

. … If the purpose of such a transaction were to avoid CCPC status in order to defeat the purpose and intent of various anti-avoidance rules applicable to investment income, including section 123.3 and subsection 123.4(2), the CRA would consider, depending on the circumstances, application of the GAAR under subsection 245(2). ...

. … In the situation where A Inc. would not be a partner of AB immediately before the time at which AB would cease to exist, we are of the view that subsection 98(5) could not apply. ...

7 October 2021 APFF Financial Strategies and Instruments Roundtable Q. 7, 2021-0899681C6 F- Stock option, Short sale and Identical property-- summary under Subsection 7(1.31) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1.31) s. 7(1.31) applies to sale of shares acquired on exercise to cover short, but not to the sale of the shorted shares An employee, who engages in a short sale transaction to finance the exercise of stock options on the shares of the individual’s employer, short sells identical shares borrowed from a third-party lender and uses the short sale proceeds to inter alia fund the option exercise – and then uses the shares acquired on exercise to cover the short position. ...

7 October 2021 APFF Financial Strategies and Instruments Roundtable Q. 7, 2021-0899681C6 F- Stock option, Short sale and Identical property-- summary under Subsection 39(4) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(4) s. 39(4) election can apply to both the dispositions occurring in connection with short sale transactions An employee, who engages in a short sale transaction to finance the exercise of stock options on the shares of the individual’s employer, short sells identical shares borrowed from a third-party lender and uses the short sale proceeds to inter alia fund the option exercise – and then uses the shares acquired on exercise to cover the short position. ...

In particular having regard to the CRA view that “to be a right or thing [under s. 70(2)] … the individual would have to be legally entitled to receive the amount at the time of the individual’s death (the right would have to exist)” CRA considered that even though an individual annuitant who died part way through the year was allocated the income that had been earned in the year up to the time of death on the T3 slip received by his executors, he had no legal entitlement to the allocated amounts. ...

However a textual, contextual and purposive interpretation of subparagraph 55(5)(e)(i) does not allow us to override its wording …. ...

However, it is still necessary to consider the application of section 84.1, subsection 245(2), as well as other relevant provisions …. ...

. … In determining if an apportionment provided under a mixed contract is reflective of the obligation of the parties under subsection 212(1), consideration would be given, amongst others, to the terms of the mixed contract and to whether the parties have divergent interests in respect of this apportionment. ...

. … In determining if an apportionment provided under a mixed contract is reflective of the obligation of the parties under subsection 212(1), consideration would be given, amongst others, to the terms of the mixed contract and to whether the parties have divergent interests in respect of this apportionment. ...