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In response to a query as to whether, where "the indebtedness with respect to a specific creditor was terminated as a result of such restructuring process…such expenses can be considered to relate ‘solely to the year' and, therefore, be eligible for deduction pursuant to paragraph 20(1)(e.1)," CRA stated: Paragraph 20(1)(e.1) of the Act provides that, notwithstanding paragraph 20(1)(e), certain financing expenses that relate only to the year they are incurred are deductible in that year. ...

The bump will not be available to Childco on the winding-up of Parentco because Parent (and, thus, Childco under s. 88(1)(d.2)) will be considered to have acquired control of Parentco at the time of its incorporation (and before the issuance of any shares of Parentco to Parent), at which time Parentco will not hold the marketable securities. ...

., residential units) that must be considered and not supplies of services by it to the residents which must be taken into account in determining whether the head lease is exempt under section 6.1, so that the lease of the assisted-living Facilities would be exempt if the "substantially all" test was satisfied on this basis. ...

.… [W]hile some of the activities, such as processing credit applications, assist FinanceCo in providing a financial service of issuing a credit card and operating and maintaining cardholder accounts, when considered as a whole [the services] are predominantly administrative in nature including storage of account information, card production services, services related to cardholder data and contact centre services. ...

If XCo is an S-Corp, although CRA has taken the position that any Canadian source income received by an S-Corp may be considered to be derived instead by its shareholders pursuant to Art. ...

29 May 2009 External T.I. 2008-0301391E5- EBITDA-- summary under Participating debt interest Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(3)- Participating debt interest acceptable for interest rate to reduce based on improved debt coverage ratio Where (in order to reflect the resulting increased credit worthiness of the borrower) the interest on a loan decreases as the ratio of debt to EBITDA of the Canadian borrower decreases, such interest will not be considered to be participating debt interest. ...

CRA stated: [A] partnership would generally be considered a taxpayer for the purposes of the subsection 97(2) rollover and could therefore rely on that subsection to the extent that the conditions set out therein are satisfied. ...

After ruling that the services of the ISO (which were a single supply including payment processing services) were excluded under s. 4(2), CRA stated:...when considered as a whole, the ISO's service is predominantly the transfer, collection or processing of information and/or an administrative service performed by a person who is not at risk (i.e., the ISO does not appear to be financially at risk when it provides assistance to the Merchant such as performing data processing, monthly reports, funds transfer and other support and administrative services). ...

CRA found that s. 17(8)(a)(ii) was not available as the Debt would not be considered to be a loan to the second CFA. ...

. … Under subparagraph 2(a) [of Article X], the S-Corp would be considered to own the shares of Canco owned by the US LLC.... ...