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Paragraph (b) of the exclusion to the investment business definition would only be satisfied if the taxpayer could establish that each particular Landco employed the equivalent of more than five employees full-time in the active conduct of its business throughout the period in question taking into consideration the services provided by the employees of USCo. ...

As "Canco did receive consideration for its disposition of the shares of FA1 in the form of the FA2 shares it received," s. 87(4)(a) applied to the disposition by Canco of its FA1 shares (assuming tht Canco did not elect to have s. 87(8) not apply), rather than draft para. ...

CRA stated: [T]he Early Termination Payment will be made by Canco to Forco as consideration for the termination of the XX under which rent would have been payable for the use of the Canadian XX Property. ...

., payments to Canadian authors in order to compensate them for the free access to their works in Canadian libraries "would be in respect of their independent literary or artistic activities" rather than (royalty) "payments… made in consideration for the use of, or the right to use, the work being lent out (or their copyright in the work)," so that in the case of a resident of Ireland receiving a PLRP payment, that payment would be taxable in Canada only to the extent that the author has a fixed base in Canada for the purposes of performing their "professional services" and only to the extent the PLRP can be attributed to that fixed base. ...

12 November 2013 Internal T.I. 2013-0497611I7 F- Feuillet T1204-- summary under Subsection 237(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 237- Subsection 237(2) T1204 disclosure applicable only where contract with federal supplier and includes travel reimbursements as “services” consideration Should reimbursements for travel expenses of external consultants to a federal agency be included on the T1204 form? ...

Before concluding that for purposes of applying the eligible capital expenditure definition to the Canadian shareholder, the expenditure incurred by it would be considered to be equal to the FMV of the property at the time of its distribution, CRA stated: [T]he cost of a property received by a corporation from its shareholder for no consideration, for example as a capital contribution, would…result in the corporation having a cost of the property equal to its FMV. ...

Before concluding that for purposes of applying the eligible capital expenditure definition to the Canadian shareholder, the expenditure incurred by it would be considered to be equal to the FMV of the property at the time of its distribution, CRA stated: [T]he cost of a property received by a corporation from its shareholder for no consideration, for example as a capital contribution, would…result in the corporation having a cost of the property equal to its FMV. ...

22 June 2016 Internal T.I. 2016-0632821I7 F- 93(2.01) & Capital Contribution-- summary under Subsection 248(5) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(5) ordinary meaning of “substituted” Canco contributed (for no share consideration) its shares of a non-resident Finco subsidiary (Luxco2 – which previously had paid exempt dividends to Canco) to another wholly-owned subsidiary (Luxco1). ...

D transferred D’s Opco shares to Holdco in consideration for a non-voting preferred share and a note. ...

After concluding that as the amounts were not legally payable, actually paying them did not bring them within the s. 104(6) rule, CRA went on to indicate that the distributions were be includible in the children’s income under s. 105(1) rather than s. 104(13), stating: [P]aragraph 105(1)(b) has no application as the provision does not apply to an interest in a personal trust that has never been acquired for consideration. ...