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.-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees Fees for legal opinions and fairness opinions obtained by a public corporation in connection with a proposed offer to repurchase a portion of its shares would be capital expenditures as such fees would be incurred in connection with a reshaping of the corporation's capital structure. Similarly, fees paid for a fairness opinion obtained in connection with a proposed amalgamation of a corporation would be considered to be capital expenditures. ...

18 May 2017 Roundtable, 2017-0692331C6- CLHIA 2017 Q3- RCAs-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 207.5- Subsection 207.5(1)- Refundable Tax- Paragraph (c) post-retirement benefits paid directly by the employer under a SERP did not generate refunds of the Part XI.3 tax paid in connection with the RCA trust established to pay related LC fees In connection with a supplemental executive retirement plan (the “Plan”), the Employer established a trust and made annual contributions to it so that the independent trustee could pay the annual fees for a letter of credit provided by a bank to pay the promised benefits in the event of the Employer’s bankruptcy. ... CRA responded: [A]n amount is not paid as a distribution under the RCA unless the amount is paid from property held in connection with the RCA. ...

The above response would also apply for s. 116 purposes in connection with valid joint elections that are filed in connection with partnership and trust interests. ...

CRA indicated that it will treat an interest payment from Canco to USco as being derived by USco in connection with USco's active trade or business in the United States for purposes of Art. ...

5 October 2012 Roundtable, 2012-0454001C6 F- Travail d'un associé d'une société de personnes-- summary under Subsection 103(1.1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 103- Subsection 103(1.1) number of employees not necessarily relevant to determining relative partner contribution CRA was asked whether, in the determination of the reasonableness of income allocated to one of the partners of a partnership, CRA considers that the importance of the work accomplished by a partner in connection with partnership activities depends on the number of employees of the partnership (with a higher number reducing the relative value of the work performed by the partner). ...

9 October 2015 APFF Roundtable Q. 19, 2015-0595621C6 F- Cash pooling and subsection 15(2)-- summary under Subsection 15(2.6) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.6) permitted use of FIFO to determine if debt repayments satisfy s. 15(2.6) CRA indicated that it does not have the discretion to not apply s. 15(2), where the applicable statutory exceptions are not available, to amounts that become owing to Canco by a non-resident affiliated Finco in connection with a cash pooling or other centralized cash management arrangement for a multinational group. ...

8 October 2004 APFF Roundtable Q. 34, 2004-0087021C6 F- Remboursement de frais de financement-- summary under Subparagraph 12(1)(x)(iv) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x)- Subparagraph 12(1)(x)(iv) reimbursement of financing expenses Would s. 12(1)(x) apply in a situation where a corporation (the "Borrower") incurred financing expenses in connection with money that was borrowed from unrelated lenders and then lent to related corporations that reimbursed the Borrower for the financing expenses that it incurred? ...

27 November 2018 CTF Roundtable Q. 13, 2018-0779991C6- 20(1)(c) & Triangular Amalgamation-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on money borrowed by parent for use in connection with a triangular amalgamation to redeem preferred shares issued by Target can be deductible In a triangular amalgamation, is the interest on a third party loan obtained by ParentCo to redeem preferred shares issued by TargetCo as part of the transaction deductible under s. 20(1)(c)? ...

27 November 2018 CTF Roundtable Q. 1, 2018-0780061C6- Allocation of safe income-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) rulings on safe income allocation to discretionary dividend shares At the 2016 CTF Annual Conference, the CRA indicated that it was conducting a study in connection with the proper allocation of safe income in circumstances involving a corporation that has issued shares that are entitled to discretionary dividends. ...

(e) of the “flow-through critical mineral mining expenditure” definition that the required certification by a “qualified engineer or geoscientist” be “completed … no more than 12 months before the time that the agreement is made,” CRA indicated that the prescribed form is in the process of being completed and will be released to the public very shortly, and that it should be attached to one of the existing forms that are already required in connection with a flow-through share offering, such as the T100A. ...