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The 2021 Explanatory Notes indicate that corporate partners may claim the s. 110(1)(e) deduction in some circumstances involving employees of partnerships, which appear to be those referred to in 2001-0115933, where CRA noted that there were no agreements in place which limited any of the employees’ employment relationship to any of the partners and that "[c]onsequently, each of the employees of the partnership are considered to be employees of each of the partners of the partnership for the purposes of section 7"- so that it should be possible to allocate the deduction among the corporate partners who are treated as employers under such policy. ...

Tyler Berg, "Registered Plan Taxes: Recent Experiences", Canadian Tax Focus, Vol. 13, No. 1, February 2023, p. 3-- summary under Subparagraph (b)(i) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (b)- Subparagraph (b)(i) Imposition of advantage tax where employees subscribe for post-freeze common shares (p. 4) 2009-0320311I7 considered that where, following a freeze transaction, a key employee subscribed for new common shares through a TFSA, the requirements of s. ...

If the taxpayer was a “fixed interest commercial trust” and was considered resident, it could potentially transfer and receive excess capacity from other eligible group entities. ...

Michael Dolson, Balaji (Bal) Katlai, Leanne Rodrigo, "Will Planning, Subsection 164(6), and Non-Resident Trusts", International Tax Highlights, Vol. 2, No. 3, August 2023, p. 15-- summary under Subsection 164(6) Summary Under Tax Topics- Income Tax Act- Section 164- Subsection 164(6) Potential inability of non-resident trust to utilize s. 164(6) for non-TCP (pp. 15-16) CRA has considered (e.g., in 2010-0384531E5) that a non-resident estate of a deceased resident may only use s. 164(6) to reduce or offset the deceased’s gain under s. 70(5) by carrying back a capital loss realized by it on shares, where such shares are taxable Canadian property (TCP). ...

[R]egulation 5907(1.4) reduces the amount otherwise prescribed to be FAT pursuant to regulation 5907(1.3) to the extent that the amount "can reasonably be considered to be in respect of" a loss or capital loss of another corporation, where that loss or capital loss would not be a FAPL of a CFA of a relevant person or partnership in respect of the taxpayer…. ... Imaginary nature of deduction/application of local rules (pp. 527-8) [U]nder regulation 5907(1.6), 2007 is a designated taxation year of FA 2, because the 2004 losses of the members of the consolidated group could "reasonably be considered" to have been fully deducted in computing US taxable income in that year. ... Multi-year perspective where local differences (p. 542) Many provisions in the Act and regulations require a taxpayer to determine whether income or profits taxes can "reasonably be considered" to have been paid "in respect of" income from a specific source. ...

Inclusion under s. 90(6) and s. 78(1) (p. 6) On January 2, 2017, if Canco has not settled its account payable, the upstream loan rules could apply to include the amount of the accrued fee in Canco's 2015 income (unless the indebtedness is considered to have arisen in the ordinary course of the lender's business). ...

., [fn no 59: [1996-1997] 188 CLR 501, 35 ATR 130.] the High Court considered the appropriate test to apply in determining whether there was an illegal purpose. ...

.-- summary under Subsection 45(3) Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Subsection 45(3) Subsequent amendments established current abuse (p.38) There is a line of authority in cases involving the GAAR in which courts considered subsequent legislative amendments as additional evidence that a taxpayer's transactions offend the object, spirit, and purpose of the Act….Examples of this approach can be seen in the decisions of the Federal Court of Appeal in Duncan v. ...

.-- summary under Paragraph 214(16)(a) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(16)- Paragraph 214(16)(a) It should be considered whether loans may be transferred among lenders prior to a particular interest payment (or prior to year end in the case of accrued and unpaid interest), in order to access a lower rate of withholding tax. ...

.-- summary under Canadian Resource Property Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(15)- Canadian Resource Property Farm-out coupled with transfer for consideration (p. 664) CRA Document 2011-0420451E5 (F) (November 22, 2011) is a recent external technical interpretation in which the CRA considered another situation involving a farm-out as part of a larger overall transaction. ...