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CRA proposed an inclusion in Canco’s income under s. 247(2) of the difference between an arm’s length price for goods sold by Canco to Sisterco LLC and the consideration paid, and also proposed a secondary adjustment under s. 247(12) on the basis that a resulting benefit conferred on Sisterco LLC was deemed to be a dividend that was paid by Canco and that was subject to a Pt. ...

LP employed the equivalent of more than five employees full time, taking into consideration the services provided by the employees of FA4. ...

If the distributions by Trust A and Trust B are made in different years, consideration should be given to whether the timing of the distributions was influenced by the discretionary beneficiaries of Trust B. ...