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. … [A] plan that otherwise meets all of the conditions in paragraph 3 of … IT-339R2 … is considered a PHSP as long as all of the expenses covered under the plan are medical or hospital expenses (“medical expenses”) or expenses incurred in connection with and within a reasonable time period following a medical expense, and all or substantially all (generally 90% or more) of the premiums paid under the plan relate to the coverage of medical expenses that are eligible for the medical expense tax credit (“METC”). ...

As a result, the Participant would be considered to have received an amount equal to the fair market value (FMV) of the Participant’s units and be required to include that amount in income from employment in the year in which the disposition occurs. ...

Headquarters indicated that such dividend was subject to Part IV tax in the hands of Holdco because the time at which it was considered to have received the s. 104(19) dividend (the calendar year end of the Trust) was in the taxation year of Holdco (commencing on July 1, 2017) throughout which Opco was no longer connected to Holdco. ...

. … [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. ...