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Respecting a requirement that there is no significant change in its membership or activities, this will not be considered to occur by virtue of a transfer of membership between parties not dealing at arm’s length or the issuance of additional memberships to them. ...

CRA responded: [T]he portion of the amount paid… in respect of the maximum…20,,, days sick leave in the Reserve at the time of retirement or in respect of the loss of employment may be considered a retiring allowance.... ...

What is reasonable or not in the circumstances remains a question of fact that can only be made once all the relevant facts of a particular situation are known and have been fully considered. ...

13 June 2017 STEP Roundtable Q. 2, 2017-0693321C6- GAAR and 21-year planning-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) abusive distribution of trust property to corporate beneficiary to defer gain for lifetimes of current beneficaries At the 2016 CTF Roundtable, Q.1, CRA considered that it generally would consider it to be an abusive circumvention of the rule for the realization by a trust of gains on its 21st anniversary (and of the related anti-avoidnace rule in s. 104(5.8)) to distribute the property of a discretionary trust to a corporate beneficiary who was owned by a new discretionary trust. ...

13 June 2017 STEP Roundtable Q. 3, 2017-0693451C6- Dual-resident estate and Article (IV)-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 double tax, not dual trust residence, generally will be addressed The estate of a deceased U.S. citizen may be considered a U.S. estate under U.S. domestic law, and also a Canadian resident estate under the ITA central management and control test or s. 94. ...

The Taxpayer considered that it had paid the accrued and capitalized interest each year, and withheld pursuant to s. 212(1)(b) and added the interest, net of withholding tax, to the balance of its debt. ...

Also, the benefits acquired by means of the additional credits will be considered to have been provided through employee contributions. ...

A who, but for this structure, would reasonably be considered to be an Opco employee, provides services to Opco on behalf of the Partnership. ...

Even if subsection 75(2) no longer applied, the attribution rules in sections 74.1 and 74.2 would have to be considered …. ...

Any dividend paid by the payer corporation is considered to be paid first out of the safe income on hand attributable to the recipient corporation's shares of the payer corporation. ...