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Regarding the likely nonapplication of s. 56(2) respecting such dividends, CCRA stated: [I]n the absence of a sham … and to the extent that sufficient consideration was given for the shares at the time they were issued, subsection 56(2) would generally not apply to dividend income since, until a dividend is declared, the profits belong to the corporation as retained earnings. ...

As consideration for corporation A issuing shares to the public, corporation A issues additional shares to corporation A. ...

For instance, the portion of the business income of a corporation for a taxation year generated by the following activities will generally be from the provision of services rather than provision of intangible property for the purposes of the TOSI rules: payments obtained as consideration for after-sales service, payments for services rendered by a supplier under a guarantee, and payments for pure technical assistance. ...

After repeating its position in Q.6-2 on its FAQ page as to the scope of the CRA policy for excluding “extraordinary items” from qualifying revenues, CRA stated: Relevant considerations in the current situation could include whether the Contractor had received payments in the past upon the temporary suspension of operations at the mine, whether the Contractor was entitled to receive compensation upon a suspension of operations at the mine under its contract with the Operator and the degree of control the Contractor had with respect to the Payments and Payment Adjustments. ...

CRA responded: “[G]ross REIT revenue” would exclude amounts that are loan proceeds and equity contributions to the extent that they do not constitute consideration to which the entity expects to be entitled in exchange for goods or services, or as income arising in the course of the entity’s activities. ...

(l) of the definition in s. 128.1(10)) held by a non-resident corporation when it became resident in Canada would not be subject to s. 70(5.3), and for purposes of determining its deemed cost under s. 128.1(1)(c), it “would be valued in accordance with normal valuation practices taking into consideration all facts relevant to the particular case.” ...

(f) of the s. 128.1(10) definition) held by a non-resident corporation when it became resident in Canada would not be subject to s. 70(5.3), and for purposes of determining its deemed cost under s. 128.1(1)(c), “would be valued in accordance with normal valuation practices taking into consideration all facts relevant to the particular case.” ...

12 September 2022 External T.I. 2021-0886441E5- Restricted Stock Unit Plan – Adjusted Cost Base-- summary under Subsection 7(1.31) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1.31) example of application of s. 7(1.31) to acquisition and immediate sale of shares pursuant to RSUs An employee who acquired 10 common shares of the employer, a public corporation, on capital account, was also issued, for no consideration (other than services rendered), 10 restricted stock units (RSUs) of the employer under an agreement to which s. 7(1) applied. ...

An employee who acquired 10 common shares of the public-company employer, was also issued, for no consideration (other than services rendered), 10 restricted stock units (RSUs) of the employer under an agreement to which s. 7(1) applied. ...

In consideration for this discontinuance, it agreed to make contributions to a trust to fund certain designated employee benefits as described in s. 144.1(1) for the New Hires. ...