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However … under subsection 256(2), Aco could elect in prescribed form for the 2004 taxation year not to be associated with either Bco or Cco. ...

For the purposes of subparagraph 81(1)(h)(i), we are of the view that the children's special allowance [so] paid … is not an amount of family allowance under the LAF and the payment of such an allowance would not preclude the exemption from the social assistance benefit that would otherwise qualify pursuant to paragraph 81(1)(h). ...

CRA responded: [S]ubsection 256(2) would not apply in the particular taxation year … because Aco and Bco would be associated with each other in the particular year but for subsection 256(2). ...

The amount of interest on the "overpayment" would be calculated at the prescribed rate … for the period from the latest of the days referred to in paragraphs 164(3)(a) to (e), taking into account paragraph 164(5)(d), to the day on which the amount is refunded or applied. ...

The EPSP trust would use an interest-bearing loan from Employerco to fund its purchase of the matching number of Employerco shares and fund the loan interest with dividends on the shares and annual contributions from Employerco – both of which were taxable income to it but with an offsetting interest deduction, so that there would be no annual income inclusion to the participant under s. 144(3). ...

Purpose of transactions [T]he main purpose of the Proposed Transactions … is to progressively place in the hands of A's heirs certain property whose FMV corresponds to the ACB resulting from the application of subsection 70(5), to the Estate, of the Holdco Shares that were acquired as a result of A's death. ...

X’s children – so that the Year 2 dividend is received directly by Ms. ...

“The borrowing capacity of Parentco and its subsidiaries significantly exceeds the maximum amount... required to complete the Proposed Transactions ….” ...

ACo will partially repay the notes referred to above (other than Note 6, which will not be repaid for a specified number of months following the commencement of the proposed transactions) in order to pay estate income tax and make specific bequests – but not so as to result in a winding-up, discontinuance or reorganization of its business. ...

The payment to a Residual Beneficiary [in 2 above] will be included in the income of a Residual Beneficiary under sections 5 and 6 of the Act in the year of receipt and will be subject to the appropriate income tax withholding …. ...