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5 December 2002 External T.I. 2002-0172315 F- Contingent Right to Acquire Shares-- summary under Paragraph 251(5)(b) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b) ss. 251(5)(b) and 256(1.4) applicable where the 3 equal shareholders agree that they must purchase the shares of anyone committing fraud – but not if redemption requirement The three equal unrelated individual shareholders of Opco (Messrs. ...

25 February 2002 External T.I. 2000-0046485 F- Majoration et Immobilisation-- summary under Subclause 88(1)(c)(vi)(B)(I) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c)- Subparagraph 88(1)(c)(vi)- Clause 88(1)(c)(vi)(B)- Subclause 88(1)(c)(vi)(B)(I) reciprocal transactions entailed acting in concert, so that the bump was denied under s. 88(1)(c)(vi)(B)(I) given resulting specified shareholder status Mr. ... X – with the result that the Subject Shares would constitute ineligible property pursuant to s. 88(1)(c)(vi), since they would be acquired by a person (HoldcoB) who was a specified shareholder of Aco during the series and before the time at which HoldcoA last acquired control of Aco. ...

14 June 2002 External T.I. 2001-0103755 F- Cumulative Eligible Capital on Amalgamation-- summary under Paragraph 87(2)(f) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(f) Amalco should not have 2 CEC adjustment times In Situation 1, Portfolioco and its wholly-owned subsidiary, Subco, which were both incorporated on February 1, 1993, amalgamated on July 1, 2001 to form Amalco and each had a positive CEC balance immediately before the amalgamation. ... Calculating the CEC on the basis that Amalco would have an adjustment time of June 30, 2001 would result in inappropriate and unfavourable tax consequences for corporations resulting from an amalgamation. … In our opinion, for the purposes of calculating the CEC of Amalco in Situations 1 and 2 described above, it should be considered that there is a continuation of the calculation of the CEC of Portfolioco and Subco in Amalco. ...

6 August 2002 External T.I. 2002-0130735 F- DISPOSITION D'UN PERMIS-- summary under Class 14 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 14 licence to operate a seniors home was eligible capital property whereas related agreements with Ministry (that after a point were not automatically renewable) were Class 14 property A corporation operated, under lease, a residential and long-term care centre pursuant to (i) a licence issued by the Quebec Ministry of Health and Social Services licences the operation of a specific number of beds at a specific location, and (ii) an operating contract and a facility use contract with the Regional Board and the Minister for a term of 13 years, including an automatic five-year renewal period, with there being no guarantee of renewal thereafter. ... Nonetheless, if the licence was attached to a specific facility and ceased to be valid when the establishment was no longer operated in that facility, it would have a time-limited duration – but that was not the case here as the licence would continue to be valid upon a change, approved by the Regional Board, in the location of the facility, so that it appeared that the licence had an open-ended duration and would be ECP. ...

12 December 2002 External T.I. 2001-0100755 F- Impact of LCB on Dr and Part IV-- summary under Paragraph 186(1)(b) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(1)- Paragraph 186(1)(b) connected dividend recipient is not required to pay s. 186(1)(b) tax if it can demonstrate by the return-filing deadline that such tax was eliminated through a loss carryback During its the taxation year ending September 30, 2000 ("2000 TY”), Bco paid its CCPC parent (Aco) a taxable dividend of $223,500, entitling it to a dividend refund ("DR") of $74,500, which reduced its total taxes payable for the year (otherwise $100,000 of Part I tax, payable on taxable capital gains) to $25,500. ... In addition, the CCRA could pay Aco interest on the amount refunded at the prescribed rate … for a particular period determined under subsections 164(3) and 187(3)... ...

12 December 2002 External T.I. 2001-0100755 F- Impact of LCB on Dr and Part IV-- summary under Subsection 164(1) Summary Under Tax Topics- Income Tax Act- Section 164- Subsection 164(1) where subsequent loss carryback eliminates the Part I tax and dividend refund (DR), the refund interest is calculated on the initial Part I tax amount even if the DR reversal is paid by set-off During its the taxation year ending September 30, 2000 ("2000 TY”), Bco paid its CCPC parent (Aco) a taxable dividend of $223,500, entitling it to a dividend refund ("DR") of $74,500, which reduced its total taxes payable for the year (otherwise $100,000 of Part I tax, payable on taxable capital gains) to $25,500. ... The amount of interest on the "overpayment" would be calculated at the prescribed rate … for the period from the latest of the days referred to in paragraphs 164(3)(a) to (e), taking into account paragraph 164(5)(d), to the day on which the amount is refunded or applied. ...

15 April 2002 External T.I. 2002-0128145 F- 84.1(2)(a.1) of the Act-- summary under Subparagraph 84.1(2)(a.1)(ii) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(a.1)- Subparagraph 84.1(2)(a.1)(ii) where old common exchanged for new common shares and prefs with s. 85(1) election equal to the pref FMV, the s. 110.6 deduction will be traced under s. 84.1(2)(a.1)(ii) only to the prefs Mr. ... X of the preferred shares would be attributable to the capital gains deduction – so that there would be a deemed dividend of $500,000 paid by Cco to Mr. ...

4 May 2009 External T.I. 2008-0299841E5 F- Garantie pour l'impôt de départ-- summary under Subsection 220(4.5) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(4.5) posting of security for departure tax can generate refund of instalments paid in excess of regular tax When an individual residing in Québec left Canada during 2002, the Part I tax payable for the year was $190,000, net of provincial abatement, but would have been only $100,000 if s. 128.1(4) had not applied. ... It should be noted that the presumption in paragraph 220(4.5)(b), providing in certain circumstances that the amount for which sufficient security is accepted is a paid amount, does not apply for the purposes of subsection 164(7). … [However] in the hypothetical situation described above, the individual could benefit from a refund of overpaid instalments of $10,000 for the individual’s 2002 taxation year. ...

Opco's "full rate taxable income" ("FRTI") for each of the years 2001 and 2005 was $198,412 and $952,380, respectively; and nil doe 2002, 2003 and 2004. ... In addition, the amount of Element B of Opco's GRIP formula was $400,000.and Subco's Element A of the formula for computing the GRIP Addition for 2006 pursuant to s.89(7) for 2002 to 2004 was nil and for the years 2001 and 2005 was $125,000 and $600,000, respectively. ... Furthermore … the amount of Holdco's GRIP is $400,000, since it seems reasonable to us to consider, in this situation, that the $400,000 dividend that Holdco received from Opco during 2001 is attributable to an amount described in Element A of the GRIP formula in respect of Opco. ...

19 April 2004 External T.I. 2004-0063851E5 F- Année d'imposition du revenu d'entreprise-- summary under Subsection 249.1(4) Summary Under Tax Topics- Income Tax Act- Section 249.1- Subsection 249.1(4) s. 249.1(1)(b) requires inclusion of partnership income in current calendar year where it ceases to carry on business in the year The individual, as a member of a partnership carrying on a business, had filed an election pursuant to s. 249.1(4) to have the fiscal period of the partnership end on May 10, so that its first fiscal period began on August 21, 2002 and ended on May 10, 2003. ... Subsection 34.1(1) does not apply in 2003 in this situation because the fiscal period of the partnership did not end after the end of the 2003 year. … [I]n 2002, the partner did not elect to add back income from that business pursuant to subsection 34.1(2). ...