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12 February 2014 Internal T.I. 2012-0443391I7- cross-border loans and deductibility of interest-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) interest deductible when satisfied with common shares issued in pre-FAD-rule foreign afiliate dumping transactions Canco purchased common shares of Foreign Sub (a subsidiary of Parentco) from its foreign parent (Parentco) in consideration for treasury shares. ...

In Year 3 LP transferred all of its shares in Forco to newly-formed "ULC" in consideration for the issuance of shares, with a joint s. 85(2) election made designating the shares' ACB as the elected amount. ...

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 that Canco did not elect to have s. 87(8) not apply), rather than draft para. ...

. … As to the nature of the income that would have arisen to Corporation at the time of the exercise of the options, we are of the view that this is consideration for the services that were to be rendered by Corporation to Publico. … Consequently, the income generated on the exercise of options granted by Publico would normally be added to the Corporation's business income under subsection 9(1). ...

A, the Directorate first noted that “For this provision to apply, the CRA must establish that the disposition of Class "F" shares of the capital stock of Opco … was part of the series of transactions or events in which Opco acquired the Class "AA" shares of its capital stock for consideration less than their fair market value,” and then stated: Although the “because of” or “in relation to” test [in Copthorne] of related transactions does not require a strong nexus, it does require more than a mere possibility or a connection with an extreme degree of remoteness. ...

21 October 2013 Internal T.I. 2013-0505831I7- Rollover and subsequent disposition of property-- summary under Paragraph 69(11)(b) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(11)- Paragraph 69(11)(b) s. 69(11)(b) inapplicable to s. 85.1(3) drop-down of CF1 to CF2 followed by sale of CF1 "exempted" by s. 2(3) The taxpayer, a Canadian corporation, transferred all its voting and participating shares of Subco, a non-resident subsidiary wholly-owned corporation, to Forco (another controlled foreign affiliate) in consideration for shares of Forco. ...

21 October 2013 Internal T.I. 2013-0505831I7- Rollover and subsequent disposition of property-- summary under Subsection 85.1(3) Summary Under Tax Topics- Income Tax Act- Section 85.1- Subsection 85.1(3) s. 69(11)(b) not applied The taxpayer, a Canadian corporation, transferred all its voting and participating shares of Subco, a non-resident subsidiary wholly-owned corporation, to Forco (another controlled foreign affiliate) in consideration for shares of Forco. ...

8 July 2013 Internal T.I. 2012-0470021I7- Settlement of Future Benefits – ASO Plan-- summary under Subparagraph 39(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(a)- Subparagraph 39(1)(a)(ii) CRA noted that an employer's group disability plan which was administered by an administrator (such as an insurance corporation) on an administrativee services only basis nonetheless would qualify as an insurance plan ("IP") (and a wage loss replacement plan ("WLRP")) for the purpose of paragraph 6(1)(f) of the Act, if it contained "an undertaking by one person to indemnify another person, for an agreed consideration, from a loss or liability in respect of an event, the happening of which is uncertain. ...

8 July 2013 Internal T.I. 2012-0470021I7- Settlement of Future Benefits – ASO Plan-- summary under Paragraph 6(1)(f) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) CRA noted that an employer's group disability plan which was administered by an administrator (such as an insurance corporation) on an administrativee services only basis nonetheless would qualify as an insurance plan ("IP") (and a wage loss replacement plan ("WLRP")) for the purpose of paragraph 6(1)(f) of the Act, if it contained "an undertaking by one person to indemnify another person, for an agreed consideration, from a loss or liability in respect of an event, the happening of which is uncertain. ...

The second part of paragraph 248(5)(a) expands the scope of this concept in envisaging an indeterminate number of substitutions, establishing a link between the initial property under consideration and the property acquired in the final substitution. ...