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Proposed transactions FA Holdco will acquire the XX % interest in FA Opco1 held by the unrelated German companies. ...

The property owned by FA1 will be transferred to a Property Co in exchange for cash or shares of that Property Co, with any such shares then being transferred by FA1 to FA Holdco in exchange for FA Holdco shares – and similarly for the real estate of FA5 and FA9. ...

. … If corporate income has not previously been taxed, whether because the corporation was entitled to certain tax benefits under the Act or for any other reason, then a dividend paid by the corporation from such income should be subject to subsection 55(2) unless none of the purposes of the dividend is described in proposed paragraph 55(2.1)(b). ...

8 October 2010 Roundtable, 2010-0373191C6 F- Computation of safe income-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) where interest in partnership holding Subco with safe income is rolled into Holdco for prefs, dividends from Subco do not change consolidated SIOH of prefs – or increase commons’ SIOH The partnership interest (in “SENC,” which holds all the shares of Subco, to which safe income is attributable) of an individual (X) was transferred under s. 85(1) at its adjusted cost base rather than its higher FMV to an unrelated holding corporation ("Holdco") in consideration for Class B preferred shares of Holdco. ...

. … [I]ncluding the value of an intercompany receivable balance pertaining to a loan made upstream as a distinct asset when determining the FMV of the wholly-owned lending subsidiary’s assets would result in the double counting… because when carrying out the gross asset value test for the parent corporation the value of the related intercompany payable balance is…ignored while the funds the parent received from the upstream loan would be included as a distinct asset of the parent…. ...

B ….. If there were three children, either Ms. A or Mr. B could claim the credit under paragraph 118(1)(b.1) in respect of the third child. ...

C in each year and making an s. 104(22) designation so that the income retains its character as U.S. source income in his hands – or could he elect under s. 94(16) so that the trust’s income will be attributed to him? ...

B will transfer various Opco shares and her Newco 2 common shares to Newco 2 under s. 85(1) in consideration for a non-interest-bearing demand promissory note equalling most of the Hard ACB of the transferred shares, and for Class B preferred shares of Newco 2 as to the balance – and similarly for Trust D&E. ...

DC1 will transfer under s. 85(1) a pro rata portion of each of its three types of property to SubDC2, SubTC1A and SubTC2 in consideration for the assumption of liabilities and the issuance of special shares, so as to satisfy the percentage test in s. 55(1) – distribution to within 1%. ...

X of the preferred shares would be attributable to the capital gains deduction – so that there would be a deemed dividend of $500,000 paid by Cco to Mr. ...