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CRA responded: The provision of the right to attend a professional development conference, workshop, seminar, or training session, would…generally be considered to be a supply of intangible personal property…. ... …[T]o be considered a service in relation to a location-specific event for purposes of section 28…the event must be the object of the service. ...

…[T]he CRA's 95(6)(b) Committee intends to review cases and assess whether they include a share investment or divestment in a foreign affiliate that could be considered to have been for the principal purpose of manipulating share ownership in the affiliate in order to secure a tax benefit, such as for example, a subsection 113(1) deduction for a stream of dividends. This may be the case where it could be considered that the share ownership in the foreign affiliate is transitory on the basis that it is reasonable to conclude that a subsequent disposition was contemplated at the outset. ...

.-- summary under Subsection 39(2) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(2) 13....Foreign currency funds on deposit are not considered to be disposed of until they are converted into another currency or are used to purchase a negotiable instrument or some other asset, i.e. foreign funds on deposit may be moved from one form of deposit to another as long as such funds can continue to be viewed as "on deposit". Term deposits, guaranteed investment certificates and other similar deposits which are in fact not negotiable, are considered funds on deposit. ...

For example, a foreign corporation with a branch that is a permanent establishment under subsection 123(1) located in Canada is not a resident of Canada but is considered a non-resident with a permanent establishment in Canada. ... For example, a corporation resident in Canada with a branch that is a permanent establishment under subsection 123(1) located in another country is not considered to be a non-resident. ...

However, where the Department is satisfied that a property is held in trust solely to carry out the terms of a will under which the ultimate and absolute ownership of that property is bequeathed to a particular individual and the trust arrangement is such that the individual's ownership rights cannot be defeated by any future event and no other person has any right whatsoever to an immediate or future benefit from that property or that trust, the property will be considered to vest indefeasibly in that individual. 2. Property is considered to vest indefeasibly in the person to whom it is bequeathed when that person has an enforceable right or claim to the ownership thereof. ...

CRA responded: The provision of the right to attend a professional development conference, workshop, seminar, or training session, would…generally be considered to be a supply of intangible personal property…. ... …[T]o be considered a service in relation to a location-specific event for purposes of section 28…the event must be the object of the service. ...

Treaty, CRA has considered many strategies designed to ensure that either Art. ... Among the strategies previously considered, the CRA is aware of some structures designed to avoid the application of para. (7) through the introduction of an interposing entity located in a third jurisdiction. ...

("This situation may be considered abusive because the Canadian taxpayer has turned an otherwise taxable receipt of monies into a non-taxable amount.") Conversely, when a Canadian parent company requests and receive a decrease in the transfer price of sales to a non-resident subsidiary without repatriation, this is not considered abusive, because s. 15(1) would apply and offset the downward adjustment. ...

After ruling that the Association is resident in Province 1 under s. 132.1(3) and s. 2(2) of the New Harmonized Value-added Tax System Regulations, No. 2, CRA noted that s. 132.1(1)(a) did not apply as the Association was federally incorporated, and stated: The Association's main office is located in [City 1] and would be considered a fixed place of activities as it is a determined location that can be identified with the Association, and the Association exercises control over that office and carries out its on-going charitable activities through that office on a regular and recurring basis. At the same time, the premises of the Members cannot be considered as fixed places of activities of the Association since, based on the available information, Members are independent in their daily operations, [and] separate legal entities…. ...

1996 Corporate Management Tax Conference Roundtable, Q. 16 (Canadian Tax Foundation), at 24:19-- summary under Distribution Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(1)- Distribution narrow scope of "reorganization" When does a reorganization end (that is, when are subsequent transactions considered part of the "reorganization" and when are they outside the "reorganization" or part of a second reorganization)? ... Thus the following transactions, occurring after a pro rata distribution and cross-redemption of shares, would normally not be considered to occur as part of the butterfly reorganization: an amalgamation of a transferee corporation with its parent; a winding up of a transferee corporation into its parent; a transfer of butterflied property by a transferee corporation a) to another shareholder of the distributing corporation; b) back to the distributing corporation; c) to its subsidiary; d) to a third party. ...