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X would not be considered, for purposes of subsection 74.4(2), to have transferred, directly or indirectly, property to Holdco. ...

[T]he existence of a separate legal entity clause contained in the Netherlands Antilles legislation governing private foundations would not...preclude an arrangement from being considered as a trust. ...

22 January 2016 External T.I. 2015-0617601E5 F- Pipeline followed by butterfly-- summary under Paragraph 55(3.1)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3.1)- Paragraph 55(3.1)(b) where pipeline transaction followed by split-up butterfly, the opco also is a distributing corporation CRA considered transactions in which, during the second year of conventional pipeline transactions, the Newco ("Corporation 2") was split between the estate beneficiaries under a butterfly reorg: The shares of the opco (“Corporation 1”), whose ACB was stepped up on death, are sold by the estate to its newly-incorporated Corporation 2 for high-PUC prefs (rather than the more usual note); after the wind-up of Corporation 2 into Corporation 1 a year later under s. 88(1), the shares (both common and pref) of Corporation 1 are distributed to the two beneficiaries; two months later, there is a split-up butterfly of Corporation 2 between the two newcos (Corporations 3 and 4) of the two beneficiaries, so that Corporations 3 and 4 between them continue to carry on the business which previously was carried on by Corporations 1 and 2. ...

Rulings Provided that the s. 248(30) conditions and the s. 110.1 receipt requirements are satisfied, the share donation in 5 will be considered a gift for purposes of s. 110.1(1)(a) and the eligible amount of the gift under s. 248(31) will be the FMV of the Donated Shares at the time the gift is made less the amount of any advantage as defined in s. 248(32). ...

The general rate income pool at the end of the year is $60,000, so that Canco is considered to have made an excessive eligible dividend designation (“EEDD”), as defined in s. 89(1), of $10,000 in respect of each eligible dividend paid. ...

In finding that in both examples, A and B are considered to carry on business in Canada through a permanent establishment as defined in Art. ...

Rulings The disclaimers by the Grandchildren will not result in any of them being considered to have received any proceeds of disposition for purposes of ss. 40(1), 106(2) and 107(1). ...

CRA now considered an example of a private-corporation employer, which in addition to establishing a defined benefit registered pension plan (RPP) for all of its employees, also established a trusteed defined benefit supplementary pension plan (an RCA) for several key owner-managers, and which purchased exempt life insurance policies on the life of certain (but not all) plan members, and with the employer contributions (after the RCA refundable tax) being used both to fund the mortality charges and to accumulate cash within the policy. ...

CRA indicated that it was not prepared to extend its policy on farm-in arrangements to this situation (given that “carrying out the work on the claims does not give a right in the claims but potentially only an option to acquire them”), stating: Consequently … the amounts paid to carry out the work on the claims of Corporation B would be added to the cash payments provided for in the agreement and would be considered part of the overall consideration given by Corporation A to acquire a property. ...

28 April 2010 External T.I. 2009-0347581E5 F- Frais de formation-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose expense incurred in course of operating real property need not have a direct effect on profit When asked whether expenses for attending a convention, seminar, luncheon meeting or other meeting incurred by an individual in the course of operating a business or an immovable are deductible under s. 9 even where there is no direct effect on profits, CRA stated: [I]n order for an expense to be considered to be made or incurred "for the purpose of", it is not necessary to show that income actually resulted from the particular outlay or expenditure itself. ...