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. … [F]or purposes of determining whether any particular location may be considered a RPE, we would generally consider an entire townhouse complex or apartment building to be one location. ...

The income earned or realized by Can Opco that can reasonably be considered to contribute to the accrued gain on the shares of Can Opco would be limited to $100. ...

Accordingly, the dividend received by the individual in that subsequent year would not be considered to have been derived from a related business for the year, so that the dividend would be an “excluded amount.” and would not be subject to TOSI. ...

However, it was not necessary to address this question “because PC1 also carries on a medical services business in Year 1 which would be considered a “related business” in respect of Spouse A.” ...

The CRA's longstanding position remains that a unit issued under a SAR plan with the above characteristics will generally not be considered to be a SDA. ...

A determination at any year end as to whether the rights of a plan participant give rise to a SDA turns on whether (i) the employee has a right to a deferred amount (which may be the case even for an ATR-45 SAR plan); and (ii) the purpose test is met (which generally is not considered to be the case for an ATR-45 SAR plan, and is a question of fact for other plans). ...

In 2017-0735771I7, Headquarters considered that such loss was suspended on the basis that, for purposes of s. 40(3.5)(c)(i), Bco was a corporation “formed” on the “merger” of CCo with BCo – with the result that BCo was deemed to continue to own the shares of CCo with which it was affiliated, notwithstanding that CCo had, in fact, ceased to exist. ...

CRA stated: [T]he forgivable portion of the CEBA is an amount described in subparagraph 12(1)(x)(iv), because it is an amount received by the taxpayer from a person described in subparagraph 12(1)(x)(i), in the course of earning income from a business, and that amount “can reasonably be considered to have been received…as a…forgivable loan…in respect of...an outlay or expense”. ...

Furthermore, the CRA took a similar approach in … 2016-0628181R3 by adding an opinion that any dividend … paid … on the shares of … the private corporation (Holdco) to the foundation (Foundation), which had previously acquired the shares as a result of the transfer of the shares by the testamentary spousal trust for the spouse of the deceased following the death of the spouse, would be considered not to be a taxable dividend, with the result that subsection 129(1. 2) would apply …. ...

Since s. 248(8)(a) provided that a transfer, distribution or acquisition of property made under or as a consequence of the terms of a taxpayer’s will is to be considered to be a transfer etc. as a consequence of the taxpayer’s death, CRA was generally of the view that the payment was made as a consequence of the individual's death. ...