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However, paragraph 75(2)(b) I.T.A. will apply when, among other things, under the terms and conditions of the trust indenture, specific provision is made that the consent of the settler of the trust or any other person who contributed property to the trust is required in connection with any decision the trustees make concerning the disposition of the trust's property. ...

Thus, in connection with the situation described, we feel that subsection 75(2) I.T.A. should apply since the common share of Opco held by the Trust could revert to the person from whom it was directly or indirectly received, that is, Mr. ...

The T3 return serves to report information about the trust itself along with information that affects the taxation of persons who have some connection to the trust. ...

It is anticipated that it will be required to be attached to one of the existing forms that are already required to be completed in connection with an FTS offering, such as the T100A. ...

Although crypto-asset mining equipment can connect directly to a blockchain network through an internet connection, most miners will prefer to connect to “mining pool” servers to increase their likelihood of receiving rewards. ...

In many cases, this equipment is housed and operated in large datacentres capable of providing the significant electricity and internet connections required for their use. ...

CRA Response The CRA response to the question posed at the 2011 IFA Conference CRA Roundtable (CRA document 2011-0404521C6) was in connection with the specific situation in which a foreign corporation (Forco) incorporated a Canadian corporation (Holdco) to acquire the shares of a Canadian corporation (Canco) which owned all the shares of an FA, and shortly thereafter Canco wound up into Holdco with Holdco then disposing of the FA shares to Forco. ...

He will also want to ensure that the value of any advantage he receives in connection with the gift can be verified so that an amount can be recognized as an eligible amount of a gift. ...

Reasons: The legislation. 2024 CTF Annual Conference CRA Round Table Question 14: Availability of the Small Business Deduction Corporation A is a Canadian controlled private corporation that carries on active business in Canada, and holds property in connection therewith. ...

Position: Since these fees would be incurred in connection with transactions of a capital nature, the said fees would generally constitute expenditures or outlays of a capital nature and their deduction as current expenses would be precluded by paragraph 18(1)(b) of the Act. ... Furthermore, any expenses in connection with the redemption of shares can be viewed as being made "once and for all", at least with respect to the shares being redeemed. ... The Queen, 95 DTC 164 (TCC), affirmed 97 DTC 5012 (FCA)), the fees incurred in connection with communications to shareholders are deductible in the computation of income as current expenses and are not disallowed under paragraph 18(1)(a) of the ITA or paragraph 18(1)(b) of the ITA, even if the communications are covering a subject of capital nature. ...