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You have confirmed that to the best of your knowledge and that of XXXXXXXXXX none of the issues contained herein: (a) is in an earlier return of XXXXXXXXXX or a related person; (b) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of XXXXXXXXXX or a related person; (c) is under objection by XXXXXXXXXX or a related person; (d) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired; or (e) is the subject of a ruling previously issued by the Income Tax Rulings and Interpretations Directorate of Revenue Canada. ...

Pursuant to subparagraph 212(1)(c)(ii), Part XIII withholding tax applies to an amount that can reasonably be considered to be a distribution to a non-resident of a capital dividend received by a trust from a corporation resident in Canada. ...

We understand that to the best of your knowledge and that of the above-noted taxpayer, none of the issues involved in this advance income tax ruling are: (a) in an earlier return of the taxpayer or a related person; (b) being considered by a tax services office or tax centre in connection with a previously filed tax return of the taxpayer or a related person; (c) under objection by the taxpayer or a related person; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (e) the subject of a ruling previously issued by the Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayer involved, none of the issues involved in the Ruling request is: (a) in an earlier return of the taxpayer or a related person; (b) being considered by a Tax Services Office or Taxation Center in connection with a previously filed tax return of the taxpayer or a related person; (c) under objection by the taxpayer or a related person; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (e) the subject of a Ruling previously issued by the Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayer involved, none of the issues involved in the Ruling request is: (a) in an earlier return of the taxpayer or a related person; (b) being considered by a Tax Services Office or Taxation Center in connection with a previously filed tax return of the taxpayer or a related person; (c) under objection by the taxpayer or a related person; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (e) the subject of a Ruling previously issued by the Directorate. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the Ruling request is: (a) in an earlier return of the taxpayer or a related person; (b) being considered by a Tax Services Office or Taxation Center in connection with a previously filed tax return of the taxpayer or a related person; (c) under objection by the taxpayer or a related person; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (e) the subject of a Ruling previously issued by the Directorate. ...

We understand that to the best of your knowledge, and that of the taxpayer involved, none of the issues involved in this ruling request is: (i) in a previously filed tax return of the taxpayer or a person related to the taxpayer; (ii) being considered by a tax services office or a taxation centre in connection with a previously filed return of the above-referred taxpayer or a related person to the taxpayer; (iii) under objection by the above-referred taxpayer or a related person to the taxpayer; (iv) the subject of a current or completed court process involving the taxpayer or a person related to the taxpayer; or (v) the subject of an advance income ruling previously issued by the Income Tax Rulings Directorate. ...

In your view Y's freeze shares are prescribed shares, within the meaning of Regulation 6205(2)(a), because: (a)     the main purpose of the arrangement was to permit some of the increase in the value of the property of Opco to accrue to X's trust; and (b)     Y should be considered not to deal at arm's length with X's trust because X and Y acted in concert to allow estate planning for the benefit of X's trust. ...

"There are, I think, three matters to be considered: a)   The character of the advantage sought and in this its lasting qualities may play a part. b)   The manner in which it is to be used, relied upon or enjoyed, and in this and under the former head recurrence may play its part and, c)   the means adopted to obtain it; that is by providing a periodical reward or outlay to cover its use or enjoyment for periods commensurate with the payment or by making a final provision or payment so as to secure future use or enjoyment. ...

May we suggest that subsections 13(5.2), (5.3) should also be considered in the event of an exercise of the option to purchase.  ...