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Cash balances which accumulate only to be depleted in accordance with the annual seasonal fluctuations of the business will generally qualify – but a permanent balance in excess of the company's reasonable working capital needs will generally not qualify. ...

. … [T]he taxable capital gain in respect of any subsequent increase in value of the mutual fund units from the date of death to the date of disposition by the GRE to the qualified donee will also be equal to zero pursuant to subparagraph 38(a.1)(i). ...

However, CRA went on to indicate that the taxpayer’s exemption threshold in this situation would be nil “it is necessary for the taxpayer to have acquired a flow-through share (or certain partnership interests …) in order for a taxpayer to have an exemption threshold in respect of a flow-through share class of property to which subsection 40(12) of the Act would apply.” ...

. … It is the CRA’s view that the intrinsic value of an option is not reflective of its FMV; rather, a valuation method that is appropriate in the circumstances should be used to determine the FMV. ...

Therefore … in the example above, the CRA would not assess interest. ...

After referring to the desirability of “timesheets, schedules, or logbooks” or payroll records showing hours, CRA recognized “the challenges presented” for demonstrating the 20-hour test for pre-2018 years, and stated: Where … information is provided in support of assertions that the 20 hour per week threshold was met in prior years, the CRA will if necessary, consider whether the assertions are reasonable having regard to such factors as The type of business and duties performed as they relate to the main activities of the business The individual’s education, training and experience Any particular knowledge, skills or know-how that the individual possessed Going forward, the ongoing maintenance of such records in respect of any family members involved in the business will ensure that businesses are able to comply with the new rules and obtain the benefits of available exclusions, even as family members leave the business. ...

CRA responded: …CRA has applied … IT-143R3 [para. 23]: “Since an outlay or expense is an eligible capital expenditure only if it is incurred for the purpose of gaining or producing income from a business, legal and accounting fees incurred in an abortive attempt to acquire shares of a corporation would normally not qualify. ...

28 September 2018 External T.I. 2018-0779261E5- Investment management fees-- summary under Subparagraph (b)(i) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (b)- Subparagraph (b)(i) proposal to impose advantage tax, where RRSP or TFSA fees are paid by the annuitant or holder, pending a Finance review In 29 November 2016 CTF Roundtable Q. 5, 2016-0670801C6, CRA indicated that it now considered the payment of fees for investment management of an RRSP, RRIF or TFSA by the plan annuitant or holder typically will be considered to be an “advantage” giving rise to tax under s. 207.05(1) equal to 100% of the fee amount (noting inter alia under the hypothetical arm’s length test in s. 207.01(1) – advantage- (b)(i) that it would not be “commercially reasonable for an arm’s length party to gratuitously pay the expenses of another party”) but that to give the investment industry time to make the required system changes, it would defer applying this new position until January 1, 2018. 2017-0722391E5 announced a one-year extension to January 1, 2019. ...

. … As such, in the example provided, ACo would be first subject to the passive income reduction in its first taxation year beginning after 2018 (i.e., ACo’s taxation year ending December 31, 2019). ...

. … In the particular situation, Partnership had a taxation year that commenced on January 1, X9 and ended immediately before the time immediately prior to the time it ceased to exist. ...