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To the best of your knowledge and that of the Taxpayers, none of the issues involved in the ruling request is: (a) in an earlier return of the Taxpayers 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 Taxpayers or a related person; (c) under objection by the Taxpayers 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. ...

Position Adoptée: a) and d) Under paragraph 12(1)(x), the forgivable portion of the loan is included in the income of the debtor in the taxation year in which the loan is received; b) The forgivable portion of the loan would be received from a person described in subparagraph 12(1)(x)(i), assuming the requirements of clause 12(1)(x)(i)(A), (B) or (C) are met; c) It could reasonably be considered that the forgivable portion of the loan has been received as assistance as a forgivable loan in respect of an outlay or expense pursuant to subparagraph 12(1)(x)(iv); e)(i) The forgivable portion of the loan would be included in the income of the corporation in its taxation year ended December 31, 2020; e)(ii) The corporation could avoid the income inclusion under paragraph 12(1)(x) by filing the election under subsection 12(2.2) with its income tax return for its 2020 taxation year to reduce the amount of allowable non-deferrable operation expenses incurred in that year; e)(iii) The corporation could avoid the income inclusion under paragraph 12(1)(x) in its 2020 taxation year by filing the election under subsection 12(2.2) with its income tax return for its 2021 taxation year to reduce the amount of allowable non-deferrable operation expenses incurred in that year; e)(iv) Where the intent of the parties is that any amount reimbursed by the corporation will be applied first in repayment of the portion of the loan that was initially forgivable, the corporation could claim a deduction under paragraph 20(1)(hh) with respect to the amount reimbursed in the taxation year in which the reimbursement is made, up to the amount included in its income pursuant to paragraph 12(1)(x). ...

We understand that to the best of your knowledge and that of each of the Taxpayers involved, none of the issues described herein are: (a) in a previously filed tax return of the Taxpayers or person related to the Taxpayers; (b) being considered by the CRA in connection with a previously filed tax return of the Taxpayers or a person related to the Taxpayers; (c) under objection by the Taxpayers or a person related to the Taxpayers; (d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; and (e) the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate of the CRA in connection with the Taxpayers or a person related to the Taxpayers. ...

The transfer of the Distributed Cansub 2 Spin Loans to TC ULC will constitute an assignment of the Distributed Cansub 2 Spin Loans by DC ULC to TC ULC such that the Distributed Cansub 2 Spin Loans will remain in existence and not be considered to be a new debt. ...

We understand that, to the best of your knowledge and that of the taxpayers involved, none of the issues involved in the Ruling request: (i) is in an earlier return of the taxpayer or a related person; (ii) is 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; (iii) is under objection by the taxpayer or a related person; (iv) is before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has not expired; or (v) is the subject of a Ruling previously issued by the Directorate. ...

In determining whether the inclusion of the dividend in the income of Canadian Resident under subsection 90(1) could be offset by another deduction or otherwise excluded from income on the basis that the income earned by S Corporation and supporting the payment of the dividend was previously included in Canadian Resident’ income as FAPI, subsection 248(28) should be considered: Unless a contrary intention is evident, no provision of this Act shall be read or construed (a) to require the inclusion or permit the deduction, either directly or indirectly, in computing a taxpayer's income, taxable income or taxable income earned in Canada, for a taxation year or in computing a taxpayer's income or loss for a taxation year from a particular source or from sources in a particular place, of any amount to the extent that the amount has already been directly or indirectly included or deducted, as the case may be, in computing such income, taxable income, taxable income earned in Canada or loss, for the year or any preceding taxation year; In this context, subsection 248(28) would not apply if the amount of the dividend paid by S Corporation that was included in computing Canadian Resident’s income under subsection 90(1) is not the same as the amount of FAPI that was directly or indirectly included in computing Canadian Resident’s income for a preceding taxation year under subsection 91(1). ...

We have considered an argument that the word "coupon" in subsection 234(1) of the Act might also include the bond residue.  ...

Where property is transferred to a corporation in exchange for shares with a par value, the transferor is considered to have realized proceeds equal to the fair,market value of the shares end not their par value. ...

We have considered an argument that the word "coupon" in subsection 234(1) of the Act might also include the bond residue. ...

We have considered an argument that the word "coupon" in subsection 234(1) of the Act might also include the bond residue. ...