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Second, a corporation that receives an eligible dividend from a payer corporation is subject to Part IV tax whether or not the payer corporation receives the DR – so that if CCRA allowed a corporation to waive a DR, this would have no effect on the Part IV tax payable by the other corporation. ...

A, who had held all the shares of HoldcoA on April 26, 1995 at which time HoldcoA held a policy on the life of A whose purpose was to fund the redemption of such shares, transferred those shares to another wholly-owned corporation (HoldcoB – all of whose shares being Class B shares were held by him) under s. 85(1) in consideration for 100 "new Class B shares" of HoldcoB. ...

. … [T]he provisions of section 22 of the Regulation will not, in and of themselves, prevent the deduction of interest on money borrowed to acquire common shares of a QBIC if there is otherwise a reasonable expectation, at the time the shares are acquired, that the holder of the common shares will receive dividends. ...

. … [T]he direct use of the borrowed money is for personal purposes, which is not an eligible use. ...

CRA responded: Under a "charitable" annuity arrangement … a donor transfers an amount to a trust in consideration for which the donor acquires a right to receive an annuity from the trust. ...

In those circumstances, we doubt that the work of the employees is of a temporary nature and, in our view, the … premium could not be excluded from the employees' income by virtue of subsection 6(6). ...

To take advantage of this election, you have to complete Form T2075 …. ...

. … [W]here after taking leave an employee retires, we are of the view that this will not generally affect the salary deferral arrangement where this was not otherwise provided for. ...

It is, however, a real and enforceable debt and therefore a true obligation …. ...

After indicating that, assuming that s. 55(4) did not apply, the s. 55(3)(a) exception applied, CRA noted: [T]his Directorate has previously taken the position that subsection 55(4) does not apply where it is shown that a parent retained de jure control of a corporation newly-formed by one of the parent’s children primarily for the purpose of protecting the parent's economic interest in the newly-formed corporation, and that none of the primary purposes of the transactions were to cause persons to become related to each other …. ...