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Rulings Include that the proposed transactions will not by themselves be considered to result in a disposition or increase in interest described in ss. 55(3)(a)(i) to (v). ...

Its deferred expenses will not be considered property for these purposes. ...

Furthermore, "any dividend paid by PC1 to Spouse A would be considered to be derived directly or indirectly from a “related business” carried on by PC2 (and not PC1) in Year 2 and subsequent years," given that the "derived directly or indirectly" phrase was to be construed broadly. ...

. … Thus, as specified in subsection 146(8.1), the executor and the Spouse will have to file Form T2019 jointly if they wish to designate the amounts that the estate received (or, as the case may be, is considered to have received) from the deceased annuitant's RRSP as a refund of premiums received by the Spouse. ...

X's will – would also be considered an acquisition of property made as a consequence of Mr. ...

(b) Does CRA still maintain its position in 9017855, that where a fee is paid to the taxpayer’s securities dealer or investment advisor allowing the taxpayer to make a specified number of trades with no additional charge until the threshold was exceeded, the taxpayer must determine the fair market value ("FMV") of the advice, administration and management services received, and only the excess is considered commissions that are therefore not deductible under s. 20(1)(bb)? ...

In the following Scenarios, is the Purchaser Corporation considered to have disposed of the Subject Shares “otherwise than by reason of death,” so that the exception in s. 84.1(2.3)(a) does not apply? ...

CRA noted: s. 110.6(14)(f)(i) provided that, for purposes of the requirement in s. 110.6(1)(b) that the shares must not have not been owned during the 24 months preceding their disposition (the “determination time”) by anyone other than the disposing individual or a related person or partnership, such shares will be considered to have been so owned prior to their issuance unless they were issued as consideration for other shares (the “original shares”). however, s. 110.6(1)(e)(i) required that throughout the period beginning 24 months before the determination time and ending at the time of the share exchange (the “substitution”), the original shares were not owned by anyone other than the individual or a related person or partnership; and that s. 110.6(1)(e)(ii) required that the original share had qualified under the asset and activity test described under para. ...

For example, instances where a trust pays the tuition fees or repays a loan taken up by another person are to be considered indirect distributions by the trust. ...

In the case of the downstream mergers, regarding the shares of the parent, the parent’s shareholder was treated as the vendor thereof and, regarding the acquisition of shares of the subsidiary, there was considered to be no vendor and the purchaser was treated as being such shareholder. ...