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Thus, the taxpayer and the corporation are "related persons" by virtue of subparagraph 251(2)(b)(iii) ….. ...

Furthermore, in our view, it is not possible to conclude that there are two separate allowances …. ...

After finding that the rent was not required to be included in their income, as there was no source of income, CRA went on to state: [W]hen disposing of a rental property … you may be able to take advantage of the principal residence exemption when disposing of the residence if the property is used as a principal residence. ...

The same reasoning would apply … for Aco, Bco and CDco. ...

Where s. 70(3) applies, the value of the deceased's rights or property will instead be included in computing the income of the beneficiary for the taxation year in which the beneficiary received it, and the beneficiary’s cost will be determined under s. 69(1.1) to equal the total of the part of the cost thereof to the deceased as had not been deducted by the deceased in computing the deceased’s income for any year, and any expenditures made or incurred by the beneficiary to acquire the property – which cost will be used to compute the beneficiary's income when the inventory is sold. ...

Y) who were unrelated persons immediately before the particular time …. ...

20 April 2005 External T.I. 2005-0119901E5 F- Associated Corporations- Shareholders' Agreement-- summary under Paragraph 256(1.4)(a) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1.4)- Paragraph 256(1.4)(a) presumption of the referenced shares being issued and outstanding is relevant only re treasury shares and does not multiply already-issued shares Two individuals (X and Y) each held all of the shares of Gesco and Holdco, respectively, and each of Gesco and Holdco held ½ of all the shares (being 50 common shares each) of Opco. ...

6 May 2005 External T.I. 2005-0116981E5 F- Rollover under section 85 of an ECP-- summary under Paragraph 14(1)(a) Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(1)- Paragraph 14(1)(a) “exempt gains balance" is of no utility in calculating the amount to be included in income under … 14(1)(a)" Mr. ...

CRA stated: [A]s indicated in … IT-479R …[t]he CRA generally presumes that: (a) the gain or loss realized by a holder of options is on the same account as the holder's transactions in shares; (b) the gain or loss realized by a writer of covered options is on the same account as the underlying shares; and (c) the gain or loss realized by a writer of naked options is normally on income account. ...