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X should also be considered in relation to Mr. X's and Ms. X's contributions to the related business, in order to determine whether the amount of interest income is otherwise a reasonable amount to Ms. ...

As to what constituted financial dependence, CRA stated: [T]he following factual elements have been considered by the courts in determining whether a party is financially dependent on another party: all or substantially all of the income earned by one party came from the other party; one party was the sole customer or supplier of the other party; the sole customer or supplier would be very difficult to replace; the integration of the activities of one party with those of the other party; the involvement or control of one party in the financing of the other party; and the contractual and commercial arrangements between the parties did not reflect terms and conditions normally agreed upon by independent parties according to commercial practices of the industry. ...

Therefore, if both spouses are considered to have beneficial ownership … they would both be required to file the election …. ...

The application of subsection 245(2) could be considered if the Pipeline Planning is structured to avoid the application of section 84.1 …. ...

It further indicated: [W]here a taxpayer’s requested amendment is fully reflected (or accepted by the Minister), the Minister will not be considered to have ascertained a different loss amount from the taxpayer. ...

Regarding Alta Energy: The SCC considered a matter central to the CRA’s ongoing efforts to protect Canada’s tax base and the integrity of its tax treaties. ...

The Directorate then stated: If a person who is subject to remittance basis taxation in Barbados files a return of income in Barbados contrary to the application of the law in force in Barbados, it is our view that the income reported on that return … would not be considered “taxed” in Barbados for the purposes of Article XXX(5) such that the benefits of the Treaty would not apply to the Income. ...

21 September 2021 Internal T.I. 2019-0807491I7- Subsections 93.1(5) and (6)-- summary under Subsection 93.1(5) Summary Under Tax Topics- Income Tax Act- Section 93.1- Subsection 93.1(5) access to ss. 93.1(5) and (6) needed for a US partnership to be considered to have a qualifying interest in a sister Opco paying it interest Canco held 100% of LLC2 through a US partnership (USP) and had an indirect 37% interest in USOpco. ...

Ss. 93.1(5) and (6) could only apply to such interest if, pursuant to the coming-into-force (CIF) provision for ss. 93.1(5) and (6) (which otherwise applied only to the 2013 and subsequent taxation years), it could be considered that the taxpayer (USP) had “elected[ed] in writing” and timely “file[d] the election with the Minister” to have ss. 93.1(5) and (6) apply to those earlier years. ...

(b) Is the safe income from the sale of the assets lost or will it be considered in a future computation of safe income? ...