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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. ...

Jenny Yu, "Departure Tax for Small Trusts", Canadian Tax Focus, Vol. 7, No. 1, February 2017, p. 8-- summary under Subsection 220(4.51) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(4.51) No relief from security requirement for small trusts/emigration under s. 94(5) (p. 8) When an individual ceases to be a resident of Canada and has a deemed disposition of certain property…[s]ecurity is automatically considered to be posted for essentially the first $16,500 ($50,000 × 33%) of federal tax (subsection 220(4.51)). ...

Jason Boland, Christopher Montes, "A Detailed Review of the Back-to-Back Loan Rules", 2016 Conference Report (Canadian Tax Foundation), 26:1-32-- summary under Subsection 15(2.18) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.18) FIFO treatment of repayments (p. 26:25) Finance has indicated that repayments are considered to occur on a first-in-first-out basis, in accordance with the CRA's general policy on shareholder loan repayments. ...

Although the strategy is technically defensible, GAAR needs to be considered…. ...

If a partnership controls Projectco, it will be considered by the CRA not to deal at arm’s length with Projectco because the partnership is treated as a person for domestic withholding tax purposes under subsection 212(13.1). ...