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IT-488R "Winding-up of 90%-Owned Taxable Canadian Corporations"-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose Cost incurred by a subsidiary in connection with the winding-up are non-deductible because they were not incurred for the purpose of gaining or producing income from a business or property of that corporation. ...

.- Q.17-- summary under Earnings Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(1)- Earnings Since under the income tax laws of the U.S. and the U.K. a payment made by one Canadian foreign affiliate to another in connection with group consolidation or group relief are not taken into account in computing the profits or loss of either company, such payments would not affect their surplus accounts. ...

16 February 2016 Ruling 165366 Dietetic Services-- summary under Section 7.1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part II- Section 7.1 nutritional consulting supplied to registered charity exempted CRA ruled that the provision by a licensed dietician of “consultant nutrition services” to a registered charity (presumably in connection with a redacted charitable undertaking of assisting needy individuals) qualified for exemption. ...

31 March 2000 HQ Letter 25522-- summary under Subsection 182(1) Summary Under Tax Topics- Excise Tax Act- Section 182- Subsection 182(1) break fee A break-up fee (referred to as a "non-completion fee") paid in connection with an aborted merger of two companies did not represent consideration for a supply, nor was it governed by subsection 182(1) as the agreement to which the fee related was an agreement for the making of an exempt financial service. ...

Income Tax Technical News, No. 41, 23 December 2009 Under "Definition of 'Tax Shelter'- Subsection 237.1(1)-- summary under Tax Shelter Summary Under Tax Topics- Income Tax Act- Section 237.1- Subsection 237.1(1)- Tax Shelter "The Maege Decisions... do not represent a departure from the requirement that statements or representations be made in connection with the property when applying the tax shelter rule; rather they adopt a broad view of this requirement, especially when sophisticated investors are involved. ...

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 23 ("Pre-incorporation Contract")-- summary under Paragraph 141.1(3)(a) Summary Under Tax Topics- Excise Tax Act- Section 141.1- Subsection 141.1(3)- Paragraph 141.1(3)(a) In response to a question on pre-incorporation contracts, CRA stated: To the extent that the adoption of a pre-incorporation contract is in connection with acquiring or establishing the commercial activities of a newly formed corporation, paragraph 141.1(3)(a) of the ETA will deem the adoption of that contract to be done in the course of the corporation's commercial activities. ...

There also is no repayment of the debt if it is assumed by another taxpayer in connection with the transfer to that other taxpayer of the assets for which the loan was contracted. ...

There also is no repayment of the debt if it is assumed by another taxpayer in connection with the transfer to that other taxpayer of the assets for which the loan was contracted. ...

May 1998 Conference for Advanced Life Underwriting Round Table, Q. 3, No. 9807000-- summary under Retirement Compensation Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retirement Compensation Arrangement Where amounts paid to an RCA are returned in some manner to the employer, Revenue Canada "may question whether or not an RCA exists, as contributions under the arrangement may not be made in connection with benefits that are to be received by the taxpayer". ...

.- Q.18-- summary under Term Preferred Share Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Term Preferred Share In determining whether an issuer of a share is controlled by a specified financial institution either alone or together with any other specified financial institution for purposes of paragraph (b), one of the factors to be considered is whether such specified financial institutions have sufficient common connections or business interests. ...