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SubCo will, by written resolution of its directors, commence proceedings for its winding-up and in connection therewith all of its property and liabilities (including its shares of NewCo2 and its partnership interest in Partnership C) will be distributed to and assumed by ParentCo, effective the date of such resolution. ... Immediately thereafter ParentCo will carry on alone the business that was the business of Partnership C and, in connection therewith, receive income from former Partnership C property and receive its share of partnership distributions from Partnership D. ... Immediately thereafter ParentCo will carry on alone the business that was the business of Partnership D and, in connection therewith, receive income from former Partnership D property and receive its share of partnership distributions from Partnership D. ...

17 May 2012 Ruling 62492-- summary under Paragraph (l) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service- Paragraph (l) supply of continuous interac processing services is exempt An "Acquirer" is a connection service provider (i.e., it provides connection to the Interac network for the purpose of processing Interac direct payment transactions) and a settlement agent (i.e., the Acquirer uses the services of a bank to provide funds). ...

CRA responded: Although section 94.2 is a relatively new provision…, the question of how to compute FAPI in circumstances where complete and full information may not be accessible is not novel, as it has historically been relevant in connection with CFA status under former subparagraph 94(1)(d) (the predecessor of current section 94.2) and paragraph (b) of the definition of "controlled foreign affiliate" in subsection 95(1). ... Additional relief in connection with reporting requirements may be available on a case-by-case basis under subsection 220(2.1). ...

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. ...

Profit- Futures/Forwards/Hedges equity swap was to hedge the risk under a capital borrowing, so that loss on closing out the swap was on capital account In connection with its monetization of the shares of a corporation, the taxpayer transferred the shares of that corporation to a Newco ("Corporation2") in consideration for shares of Corporation2, entered into an equity swap with a financial intermediary with respect to the shares of Corporation2 under which it agreed to pay the appreciation in the value of the shares of Société2 above a ceiling level, and the counterparty agreed to pay the depreciation in value of the shares of Corporation2 below a floor level, and the taxpayer borrowed money from another financial institution. ... Given the close connection between the loan and the equity swap contract, including the fact that the amount of the loan corresponded to the floor value of the swap contract, the loss sustained by the taxpayer when the equity swap was settled was on capital account. ...