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31 March 2003 External T.I. 2002-0171835 F- DON D'ACTIONS COTEES EN BOURSE-- summary under Subsection 149.1(6.3) Summary Under Tax Topics- Income Tax Act- Section 149.1- Subsection 149.1(6.3) donation of Pubco shares to public foundation qualified as such given that s. 149.1(6.3) designation not effective until following year A taxpayer made a gift of listed shares to a public foundation as defined in section 149.1 which, by virtue of the gift representing more than 50% of the foundation’s capital (without regard to an alleviatory amendment effective December 20, 2002) would cause it to become a private foundation instead. ... Consequently … the capital gain realized in respect of the donation of shares listed on a prescribed stock exchange to such a public foundation will qualify for the [rate] reduction under paragraph 38(a.1). ...

6 December 2001 External T.I. 2001-0113375 F- PLACEMENT REER NASDAQ-- summary under Paragraph 4900(1)(s) Summary Under Tax Topics- Income Tax Regulations- Regulation 4900- Subsection 4900(1)- Paragraph 4900(1)(s) no deemed acquisition if pink-sheet stock is held after December 31, 2001, but tax on FMV at actual acquisition time applies Regarding the treatment of shares listed on the Nasdaq over-the-counter market, CCRA stated: [W]here paragraph 4900(1)(s) of the Regulations applies to a property to cause it to be prescribed as a qualified investment until December 31, 2001, there is no acquisition on January 1, 2002 of a non-qualified investment. … [I]f a trust governed by an RRSP or a RRIF continues to hold property after December 31, 2001 to which paragraph 4900(1)(s) of the Regulations applied, the tax that the trust will have to pay under Part XI.1 of the Act will be computed at 1% of the fair market value of the property at the time it acquired it. ...

That corporation had no income in 2001 and 2002, and small income in 2003 from software development. Before concluding that “the new corporation did not carry on a business at the time the shares were issued” so that “those shares were not shares of an eligible small business corporation,” CRA noted that there was no evidence that “a software development activity … [had] started at the time the taxpayer invested in the corporation,” and also stated: [T]here may be arguments that the business was started at the time that steps to change the zoning were taken. ...

16 November 2006 External T.I. 2006-0203131E5 F- Régime à traitement différé-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) advances received were salary rather than loans and, when repaid, reduced employment income An employee signed a deferred salary leave contract for the period from June 29, 2002, to December 29, 2006, with his leave being taken from May 14 to November 11, 2005. ... However, in the year of resignation, i.e. 2006, since the salary for the last two pay periods was withheld to recover part of the prepaid salary, the amount of salary received by the employee- net of the deductions made by the employer – was to be included in the employee's income for 2006 In addition, any cheques written by the employee in 2006 for prepaid salary reimbursements would reduce his employment income for 2006 and, if repaid in 2007, would reduce the employee's 2006 employment income, so that the employer would be required to file an amended T4 slip for that taxation year. ...

In 2002, each of ABCco and DEFco received a taxable dividend of $800,000 from the other on a cross share redemption. ... The result is the same whether the circular calculations begins with the $800,000 dividend paid by one of the corporations, or the other …. 4 th Situation This is identical to the 3 rd, except that, in 2004, ABCco paid a taxable dividend of $100,000 to its parent. ...

In light of the joint and several liability of the resident contributor under s. 94(3)(d) for unpaid taxes of the trust for its 2020 taxation year, subject to limitation by the “recovery limit” provisions of ss. 94(7) and (8), would the resident beneficiary be liable for such taxes given that the beneficiary did not receive any distributions from the trust in its 2002 taxation year; and would a distribution to the beneficiary in subsequent taxation years affect the Minister’s ability to collect in respect of the trust’s 2020 taxation year? ... The Minister could, however, assess the resident beneficiary for an amount not exceeding $100,000 on December 31, 2022 given that the conditions in s. 94(7) were by assumption satisfied for the 2020 year – and this was so even if s. 94(3) had ceased to apply to the trust for its 2021 or 2022 taxation year. ...