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In addition, payments made for the purchase of works of art from a self-employed artist such as under an art bank program are considered to be ordinary business income to the artist …. 1.29 The Canada Council for the Arts distributes annual Public Lending Rights (PLR) payments to Canadian authors through the PLR program as a form of discretionary cultural support to eligible individual creators of literary and scholarly works that are found in the public library collections. ...

. … 1.94 It is the CRA's view that any accrued foreign exchange gain or loss on a foreign currency denominated debt which is extinguished on an amalgamation of the debtor and the creditor and is deemed to be settled by virtue of subsection 80.01(3) will not be realized as a consequence of the amalgamation. ...

S4-F7-C1- Amalgamations of Canadian Corporations-- summary under Subsection 87(9) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(9) allocation of s. 87(9)(c)(ii) excess as parent chooses 1.12 … In general terms, this [s. 87(9)(c)(ii)] additional amount is equal to the amount by which the tax cost of the assets (less liabilities) of the new corporation immediately after the amalgamation (as described in subclause 87(9)(c)(ii)(A)(I)) exceeds the total of the adjusted cost bases to the parent of the shares of the predecessor corporations owned by it immediately before the amalgamation (referred to in this paragraph as the excess). ...

Subsection 248(36) applies if: a. the deemed fair market value rule applies because the taxpayer acquired the gifted property within the 3-year or 10-year period described in ¶ 1.27(a) and (b); and b. the gifted property had been acquired at any time in that 3-year or 10-year period by any person or partnership that does not deal at arm’s length with the taxpayer. ...

. … 1.29 [I]t is possible for each of two unrelated persons to be regarded, for the purposes of subsection 251(2), as having control of the same corporation at the same time. ...

No other property may be designated as a principal residence for any of those years by the taxpayer (or, for any of those years that are after the 1981 tax year, by the taxpayer or any of the other members of his or her family unit) as discussed in ¶ 2.13- 2.14. ...

. … 1.13 Usually the frequency and systematic nature of an activity would be indicative of a business. ... More recently, the Tax Court of Canada went on to state that: … Gambling- even regular, frequent and systematic gambling- is something that by its nature is not generally regarded as a commercial activity except under very exceptional circumstances. ...

. … 1.18 A lottery has been defined as a scheme for distributing prizes by lot or chance among persons who have purchased a ticket or a right to the chance. ...

Further, subsection 84(3) will not otherwise apply to deem a shareholder of a predecessor corporation to have received a dividend where the shareholder exercises its statutory dissent rights in respect of the amalgamation and receives payment for its shares from the new corporation.... 1.6 Regarding the condition described in ¶1.1(c), the CRA will not ordinarily apply subsection 245(2) to an amalgamation that is undertaken to squeeze out minority shareholders whereby the redeemable preferred shares received by the minority shareholders are redeemed shortly after the amalgamation (see paragraph 28 of Information Circular 88-2, General Anti-Avoidance Rule – Section 245 of the Income Tax Act). 1.35 Where one predecessor corporation has a leasehold interest in a property owned by a second predecessor corporation, the application of section 87 to the amalgamation will only be accepted where subsection 13(5.1) is applied concurrently as if the new corporation is the same corporation as, and a continuation of, the first mentioned predecessor corporation.... ...

Consequently, subsection 87(3.1) permits the new corporation to elect not to have the provisions of subsection 87(3) apply where both of the following conditions are satisfied: (a) all of the issued shares of each class of shares (other than a class of shares all of the issued shares of which were cancelled on the amalgamation) of each predecessor corporation are converted into a separate class of shares of the new corporation; and (b) after the amalgamation, the number of shareholders of each class, their proportionate ownership of each class, the number of issued shares of each class, the issued capital of each class for corporate law purposes and the terms and conditions of each class of shares of the new corporation are identical to those that existed for the particular class of shares of the predecessor corporation which were converted into that separate class of shares of the new corporation. 1.89 If the conditions in … (a) and (b) are satisfied and the new corporation elects in its return of income for its first tax year to have subsection 87(3.1) apply, each class of shares of the new corporation issued on the amalgamation will be deemed to be the same class as, and a continuation of, each class of shares of the predecessor corporation converted on the amalgamation for the purposes of computing their paid-up capital. ...