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Attribution pursuant to subsection 75(2): In document 2010-0366301I7 we considered an audit in which a taxpayer who was the sole trustee and was a capital beneficiary of a trust, had transferred property to the trust by accepting undervalued freeze shares as consideration when growth shares were issued to the trust. ...

Subsection 18(4) denies a deduction for a portion of a corporation's total interest paid or payable to specified non-residents through consideration of the appropriate portion of non-resident debt-to-equity. ...

Accordingly, we have not had the opportunity to give full consideration to whether the above position should apply for purposes of that provision. ...

À notre avis, malgré que certains facteurs et éléments factuels pris isolément puissent sembler courants et apparaître neutres, la prise en considération d'un ensemble de facteurs propres à une situation particulière donnée est susceptible de teinter la localisation de la gestion centrale et du contrôle de la fiducie impliquée. ...

If the newly incorporated CCPC (the pipeline corporation) has simply acquired the shares of the original corporation from the estate for consideration of a promissory note and has never commenced to carry on a business prior to distributing its property to the estate, the distribution of property to the estate could not have occurred on the discontinuance or reorganization of its business. ...

5 October 2012 APFF Roundtable Q. 13, 2012-0454181C6 F- Discretionary Dividend Shares CRA Tags 15(1) 245(2) 110.6(7) Principal Issues: Whether the issuance by an operating corporation of discretionary dividend shares of its capital stock to a holding corporation for nominal consideration, as part of an asset protection plan, would be subject to any anti-avoidance provisions of the Act or would be acceptable in terms of tax policy? ...

Dans le cas d'une PME, cela peut être pour diverses raisons (non-rentabilité pendant les premières années, nécessitée de réinvestissement des liquidités ou simplement pour des considérations d'efficacité fiscale). ...

Position Adoptée: 1- Additional income tax paid would reduce safe income on hand of Opco. 2- Same as in first scenario for Opco and reduction of the cost of shares of Opco for Purchaserco 3- Same as in first scenario but impact of paragraph 12(1)(x) and subsection 12(2.2) must be taken into consideration. ...

Does the calculation of the average annual rate of return take into consideration the paid-up capital of the shares intially acquired or the commuted value of the preferred shares in a freeze? ...

During our consideration of that request, the GAAR Committee expressed its view that a Canco's acquisition of an FA's preferred shares was an avoidance transaction which would, when combined with the payment of exempt dividends thereon and the Canco's disposition of previously held common shares of the FA, result in the avoidance of subsection 93(2.01) (and 93(2) as it formerly read). ...