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Accordingly, in ruling requests on this type of transaction, considered in 2012, we refused to confirm that section 84.1 would not apply to deem employees to receive a dividend from a Buyco on the disposition of their Opco shares. ...

Furthermore, where a future income tax asset becomes a tax receivable, this tax must be considered as an asset in determining whether a share is a QSBCS or if a corporation is an SBC. ...

. … However, when a future income tax asset becomes a tax receivable, such tax receivable must be considered as an asset for determining if a share is a QSBCS or a corporation is a SBC. ...

. … Income that is not incidental will usually be considered to be income of the unit owners, if this is appropriate under the relevant provincial law. ...

CRA found that s. 56(4) applied to Corporation on the basis that the Corporation, as the consultant, was the party entitled to the options, would have recognized business income on exercise of the options and on the facts of the situation it could be considered that the rights to such amount were transferred or assigned by it to Ms. ...

. … Income that is not incidental will usually be considered to be income of the unit owners, if this is appropriate under the relevant provincial law. ...

…[T]he stream of income payable from a LRIF or LIF would not be considered a life annuity, as the annual payments are determined each and every year by reference to the current fair market value of the property of the LRIF or LIF, and the annuitant has discretion to select the total payments to be made each year within the range permitted by the applicable income tax and pension rules. ...

Respecting the deductibility to the Taxpayer of costs incurred respecting Sellers who provided their services through corporations, CRA stated (TaxInterpretations translation): [If] they are considered to have received a benefit in respect of, in the course of, or by virtue of their office or employment…the value of such benefit must be included in the computation of their income by virtue of paragraph 6(1)(a) even if the trip is paid for by a person other than their employer. ...

As such, the PLOI election in respect of the New Loan cannot be made or, if it was made, it would be considered invalid with the result that no interest income under subsection 17.1(1) would be imputed to the Canadian lender in respect of the New Loan. ...

S. 85.1(4) was not considered here because there was to be a separate referral on that issue. ...