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Situation (b) Moreno: The same considerations as above would be relevant. ...

A Folio is our web-friendly technical publication that takes consideration of the state of the law, and relevant Tax Court decisions and technical interpretations that the CRA has produced up until the date of the Folio publication. ...

As provided for in subsection 256(5.11) and the applicable jurisprudence, any factor, whether contractual, commercial, economic, moral or familial, may be taken into consideration in order to determine whether a person or group of persons has influence, direct or indirect, the exercise of which would result in de facto control of a corporation ("Influence"). ... Under paragraph 80(2)(a), an obligation issued by a debtor is settled at any time where the obligation is settled or extinguished at that time (otherwise than by way of a bequest or inheritance or as consideration for the issue of a share described in paragraph (b) of the definition excluded security in subsection 80(1). ...

However, it is not uncommon for a shareholder to request an S Corporation agreement and, while the request is under consideration, file the Canadian returns in the expectation that an S Corporation agreement will be provided. ...

A's right under the Initial Trust constituted a beneficial interest, if subsection 248(25) applied without taking into consideration subdivisions (b)(iii)(A)(II) to (IV) thereof. ...

Example 4: Shareholders of DCco transfer shares of DCco having an aggregate PUC of $10,000 and an ACB of $1,000 to TCco in consideration for shares of TCco. ...

To that end, the CRA maintains a strong and meaningful relationship with the Department of Finance which includes engaging in ongoing discussions about proposed legislative measures, where consideration is given to the administrative feasibility of new tax measures, any associated taxpayer burden, and the resources required to implement and administer new measures. ...