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Various considerations for structuring a market maker trust (i.e., a trust established by the private corporate employer, with itself as beneficiary, to effect purchases and sales of shares of employees other than specified employees so as to give them capital gains rather than deemed dividend treatment) are discussed. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2025-07-09 26 February 2025 Internal T.I. 2023-0985151I7 F- Remboursement de frais juridiques par un actionnaire à sa société / Reimbursement of legal fees by a shareholder Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense contingent dividend prospect likely did not support a deduction for an obligation to reimburse legal fees Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees the vendor’s agreed reimbursement of the sold corporation’s legal costs of a failed suit in consideration for a dividend had the suit succeeded, likely was non-deductible Income Tax Act- Section 42- Subsection 42(1)- Paragraph 42(1)(b)- Subparagraph 42(1)(b)(ii) s. 42(1)(b)(ii) might apply to the vendor’s agreed reimbursement, post-sale, of the sold corporation’s legal costs of a failed suit 22 May 2024 External T.I. 2024-1016211E5 F- Mineral Resource Cert- XXXXXXXXXX Income Tax Act- Section 248- Subsection 248(1)- Mineral Resource- Paragraph (d)- Subparagraph (d)(i) NRC certification received 2000-06-09 11 May 2000 External T.I. 2000-0009605 F- Démolition d'un immeuble Income Tax Regulations- Regulation 1100- Subsection 1100(11) Reg.1100(11) does not limit a terminal loss Income Tax Act- Section 20- Subsection 20(16) rental property restriction rule does not apply to a terminal loss Income Tax Act- Section 13- Subsection 13(21.2) s. 13(21.2) does not apply to an individual nor to a corporation demolishing a building while retaining the land for more than 30 days Income Tax Act- Section 54- Superficial Loss no superficial loss where demolition of building Income Tax Act- Section 40- Subsection 40(3.3) no suspended loss where demolition of building 15 May 2000 External T.I. 2000-0001995 F- CONGE SANS SOLDE-REGIME DISTINCT Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) payment of premiums by employee during unpaid leave did not create a separate plan, so that any benefits received would still be taxable 11 May 2000 Internal T.I. 2000-0008270 F- Perte finale disposition bâtiment Income Tax Act- Section 13- Subsection 13(21.1)- Paragraph 13(21.1)(b) s. 13(21.1)(b) would apply to reduce terminal loss even if the land was disposed of at a loss in a previous year 24 May 2000 Internal T.I. 2000-0017677 F- PENSION ALIMENTAIRE Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount payments made pursuant to a separation agreement in order to maintain a financial balance between them rather than for maintenance, were not support amounts 17 May 2000 External T.I. 1999-0011695 F- Revenu protégé- options et dividendes follow-up in 2000-0040405 F Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) safe income of Pubco allocated to option granted to a minority shareholder to acquire its shares, but reduced by Pubco dividends 17 March 2000 APFF Roundtable Q. 11, 2000-0008260 F- DEDUCTION POUR PLACEMENTS Income Tax Act- Section 181.2- Subsection 181.2(4)- Paragraph 181.2(4)(b) balance of sale, although a debt, is not a “loan or advance”/ prepaid expenses are “advances” ...