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Thus, if an entity is treated as a corporation under Canadian tax law but is treated as an entity without share capital under the relevant foreign tax law, an investment in this entity could be considered a hybrid investment that is subject to the FTCG Rules. ...

If a CRIC participates in cash-pooling arrangements with its foreign affiliates, any cash-pooling loans to these affiliates could be considered investments subject to the FA dumping rules. ...

Robert Kopstein, Rebecca Levi, "When Should the Courts Allow Reassessments Beyond the Limitation Period", Canadian Tax Journal, (2010) Vol. 58, No. 3, 475-527-- summary under Solicitor-Client Privilege Summary Under Tax Topics- General Concepts- Solicitor-Client Privilege In the course of an extensive criticism and review of s. 152(4)(a)(i), the authors stated (at pp. 521-22): A related issue arises where the CRA proposes to reassess a taxpayer under subparagraph 152(4)(a)(i) on the basis of a disputed filing position, and in so doing seeks information as to the specific advice received and considered by the taxpayer in a legal opinion....... ...

Although the dual resident article provides a series of rules by which the taxpayer is considered to be a resident of only one of two states for purposes of the treaty, the absence of the other income article means that the treaty does not extend to this other income of the taxpayer. ...

X, No. 1, 2015, p.694-- summary under Subsection 15(1.2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1.2) Priority of s. 15(1.2) rule (pp. 698-9) [T]he existence of this rule suggests that a forgiven shareholder loan will typically be considered a shareholder benefit under subsection 15(1) unless one of the exceptions to that rule applies. ...

be considered a "dead asset" as a matter of policy. Consequently, investments in a PLOI are not subject to the FAD Rules. ...

Accordingly, planning to utilize or move other more valuable tax attributes prior to the debt forgiveness should be considered (p. 6) ...

Importantly, these NOLs should not be considered NOLs of Pubco for the year of Pubco ending before compromise, and therefore they should not be reduced by any forgiven amount of Pubco that arises in the year of Pubco in which the debt settlement occurs..... ...

Knowhow might be considered to have been disposed of only if the transferor can no longer avail itself of the knowledge in question—for example, where it sells the business to which the knowledge relates. ...

. … Subsection 12(9.1)…exclud[es] from the certificate holder's income the portion of the proceeds of disposition received by the certificate holder from the disposition of an interest in the mortgage loan that can reasonably be considered to represent a recovery by the certificate holder of the cost of acquiring the interest [see 9206645]. … Conversely… subsection 20(21)…should allow a deduction of the overaccrual on the disposition of the certificate for fair market value. ...