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2012 Ruling 2011-0431051R3 - Charity's interest in a taxable corporation -- summary under Paragraph 149.1(2)(a)

. … [T]he Charities Directorate…have advised us that… the performance of XX services by the Charity to Newco would be a business that is not a related business. ...

30 April 2013 External T.I. 2013-0475271E5 F - CCTB - Marital Status Change -- summary under Paragraph 122.62(7)(b)

. … Mr. B's income will not be considered in setting the CCTB for the months before July 2012 since paragraph 122.62(7) (b) applies only to a month that begins after a change in marital status. ...

21 August 2014 External T.I. 2014-0527611E5 - T1135 for Deceased Individual -- summary under Subsection 233.3(3)

This combined value should be included in Category 6 of Form T1135, " Other property outside of Canada. ...

25 August 2015 External T.I. 2015-0571271E5 F - Affiliated Trusts under Paragraph 251.1(1)(h) -- summary under Contributor

X would also, by virtue of subparagraph 251.1(4)(d)(i), be a majority interest beneficiary of Trust B… … Trust A and Trust B would thus be affiliated…by virtue of subparagraph 251.1(1)(h)(i)…. ...

2015 Ruling 2014-0559181R3 - Internal Reorganization -- summary under Paragraph 55(3)(a)

. … [or that the] Proposed Transactions… will have any material impact on the trading price of the shares of the capital stock of Ultimate Parentco or the value of the options held by the Optionholders. ...

11 March 2013 External T.I. 2012-0469231E5 F - Deferred terminal loss -- summary under Paragraph 13(21.1)(a)

CRA responded: [T]he elements applied to determine the proceeds of disposition of the building according to the calculation rules set out in paragraph 13(21.1)(a) … are, inter alia, the fair market value of the land immediately before its disposition and its cost amount to the vendor. ...

10 August 2015 External T.I. 2015-0602751E5 - Capital gains deduction and section 84.1 -- summary under Paragraph 84.1(2)(a.1)

. … If instead of selling the shares to you and your wife, the Shareholder had sold the shares of the Corporation to Holdco and received a note, subsection 84.1(1)(b) of the Act might apply to deem the Shareholder to have received a dividend on the disposition of the shares. ...

15 December 2014 Internal T.I. 2012-0445361I7 F - Remboursement de frais de déménagement -- summary under Eligible Relocation

. … ...

7 December 2015 External T.I. 2015-0585171E5 F - 7(1)(b) benefit and 110(1.1) election -- summary under Subsection 110(1.1)

. … The Corporation appears to be the particular qualifying person which has agreed to issue or sell the shares. ...

24 December 2015 Internal T.I. 2014-0560831I7 - International shipping -- summary under Paragraph 81(1)(c)

. … [T]he Taxpayer would need to demonstrate that the ship owner is operating the ship under the Taxpayer’s direction and not, in effect, under the direction of the Related Party Customers. ...

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