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. … [S.. 6(6)(a)(ii) is unavailable as] generally, a location is considered remote if the nearest established community of 1,000 or more is at least 80 kilometers (50 miles) by the most direct route normally taken in the circumstances. ...

The correspondent considered that the retained earnings of ULC should exclude its proportionate share of the Partnership income for the stub period on the basis that " 2007-0248961R3 indicate[s]... that section 96 informs the determination of the amount of partnership income to be included in determining the amount of a corporate partner's retained earnings for the purpose of the thin capitalization rules. ...

" CRA also noted [TaxInterpretations translation] that although IT-64R4 indicates that the holding of a large debt is relevant to determining whether the holder has de facto control of the debtor: This factor nonetheless was considered of little importance in Technical Interpretation XXX where the debt represented virtually all the net value of a corporation but all its assets consisted of readily marketable securities which could serve to repay the debt held by an estate without imperiling its investment operations. ...

Respecting whether Targetco would be considered to have made an "excessive eligible dividend designation" under (c) of the definition, CRA stated (TaxInterpretations translation): In the situation described above, Targetco is the only corporation which will pay a dividend and whose GRIP will be reduced. ...

This approach appears to us to be further justified by the fact that the determination of the place of residence of a trust, although generally made at one time, may require that factors and factual elements relating to an extended period be considered. … [T]he fact that a person advises a trustee should not in itself generally alter the location of central management and control of the trust at the trustee level. ...

In this context, what is an "arrangement" and when is it can be considered to end? ...

Generally, the carrying on of a trade or business directly attributable to, or connected with, pursuing the non-profit goals and activities of an association will not cause it to be considered to be operated for profit purposes. ...

Would a gain be considered to arise where the property (which is taxable Canadian property) is located (Canada) or where the transaction is completed (in Japan)? ...

After noting that the interest of the beneficiary of a discretionary trust "is essentially a right… to be considered by the trustee as to whether or not any trust property…should, in the trustee's discretion, be distributed…see Gartside v. ...

24 February 2014 External T.I. 2013-0505391E5 F- Clause de earnout renversé-- summary under Subparagraph 40(1)(a)(iii) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(1)- Paragraph 40(1)(a)- Subparagraph 40(1)(a)(iii) a sale price that is subject to a reverse earnout is not considered to be payable after the year (no reserve) CRA confirmed its position in 2000-0051115 that: Where the cost recovery method is not used and the sale price of a property is not certain at the time of the disposition because of an earnout agreement, a taxpayer may estimate the proceeds of disposition and use this amount to compute the capital gain or capital loss pursuant to subsection 40(1) of the Act. ...