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We have not summarized, or translated the responses to, Q.1 and Q.3, for which CRA indicated that the answers were still under consideration. ... CRA Preliminary Response to Q.8(b) The term "retirement income fund" is defined in subsection 146.3(1) as an arrangement between a carrier and an annuitant under which, in consideration for the transfer to the carrier of property, the carrier undertakes to pay amounts to the annuitant and, where the annuitant so elects, to the annuitant’s spouse or common-law partner after the annuitant’s death. ...

Question 1: Safe Income and Preferred Shares The Canada Revenue Agency (CRA) has considered the allocation of safe income to preferred shares where a shareholder acquires preferred shares in a corporation as consideration for the transfer of a property (other than shares) on a tax-deferred basis to the corporation. ... CRA Response As part of the Safe Income Paper, the CRA did state that where a shareholder acquires preferred shares of a corporation as consideration for a transfer of a property on a tax-deferred basis to the corporation, the accrued gain on the property at the time of the transfer and that would subsequently be realized by the corporation would indeed be viewed as contributing to the gain on the preferred shares and would be included in the safe income of the preferred shares. ... With respect to the nature of the financing provided by NR1 (the ultimate funder) to NR2 (the intermediary), the following considerations are relevant. ...

Implementing reporting Thus, implementing the reporting involves considerations of the timing, the scope and the conditions for use. ...

So I throw that out for your consideration. Most people have acknowledged that 15 months is too long. ...

The determination of whether these provisions could apply on the transfer of property from Trust to NewTrust would require consideration of all the relevant facts and circumstances, including the terms and conditions that apply in respect of Trust and NewTrust. ... Ata particular time on November 1, 2020, ACo purchases for cancellation all of its shares owned by BCo for consideration that exceeds the aggregate paid-up capital of those shares, resulting in ACo being deemed to pay a dividend, as computed under subsection 84(3) (“Deemed Dividend”) at that time, to BCo. ...

Consequently, subject to a consideration of the provisions of the will as a whole and the applicable law, it is possible that the conditions of subsection 104(18) could be satisfied in respect of the child or children of the deceased who are beneficiaries of the estate and who have not attained 21 years of age at the end of a particular taxation year. ... Official Response 7 October 2021 APFF Financial Strategies and Instruments Roundtable Q. 7, 2021-0899681C6 F- Stock option, Short sale and Identical property Q.8 Pipeline where sale to existing corporation rather than Newco In order to implement pipeline planning, the estate of an individual ("Estate") generally incorporates a new corporation ("Newco") to which it sells shares of a private corporation ("Target"), with or without a tax rollover, in consideration for shares of Newco (the "Shares") or a note issued by Newco ("Note"). ...

In our view, a power of attorney under which a designated attorney exercises the voting rights of the controlling shareholder of a corporation as a consequence of the incapacity of the shareholder (who continues to be the legal and beneficial owner of the shares), would not constitute an external document that is to be taken into consideration in determining de jure control of the corporation. ... New subsection 245(4.1) of the general anti-avoidance rule (“GAAR”) provides that if an avoidance transaction is significantly lacking in economic substance it is an important consideration that tends to indicate that the transaction results in a misuse or abuse under subsection 245(4). ...

In some of these circumstances, consideration can be given to whether it may be better for taxpayers to determine whether the amount is excluded from the TOSI because it is a reasonable return of the individual based on the factors applicable in the circumstances. ... Section 84.1 achieves its purposes by: (1) reducing the paid-up capital of the shares of the subject corporation, which reduces the ability to return paid-up capital of the purchaser corporation as the excess would be taxed as a dividend, and (2) deeming the individual shareholder to have received a dividend where the purchaser corporation pays non-share consideration for the shares of the subject corporation that exceeds the greater of the paid-up capital and the “hard ACB” of the particular shares transferred. ...

The initial folios workload was prioritized for action based on considerations that included: feedback received through internal and external consultations to identify the public need for guidance in each technical subject area; and the availability of resources to prepare the required updates. ...

Finally, consideration should be given to the possible application of other provisions of the Income Tax Act, depending on the facts and circumstances of the particular situation, such as subsection 56(2), if it were otherwise determined that the loan was not made in good faith. ...