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In this regard, CRA noted its position that, in the absence of evidence to the contrary, it considered there to be a presumption that all the trustees would constitute a group, so that generally all such trustees would need to be members of the child group. ...

CRA indicated that, to ensure that the trust account number for the bare trust is no longer considered active or open, the trustee may: (i) send a letter to the trust tax centre indicating that the bare trust has ceased to exist, and providing the trust account number, the bare trust name and the date on which it ceased to exist; or (ii) file a final T3 return for the 2024 tax year with the date on which the bare trust ceased to exist. ...

17 June 2025 STEP Roundtable, Q.2-- summary under Paragraph 84.1(2.31)(d) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2.31)- Paragraph 84.1(2.31)(d) trustees are not considered to be owners of the shares held by the trust Could shares which did not amount to control of the particular corporation be held by a trust where the parent and the parent's spouse or common-law partner (the “parents”) were the sole trustees or a majority of the trustees? ...

Although the time of an amalgamation was generally considered to be the earliest time on the date of amalgamation in the absence of a particular time being specified in the certificate of amalgamation, here: [F]or the purposes of determining whether the shares of the capital stock of Targetco qualified as a QSBCS at the time of their disposition by Mr. ...

To the extent that, until the Issuance Event, the SAFE is not considered to be a share under the applicable corporate statute and does not confer any of the rights or impose any of the obligations generally associated with a share under such statute, the CRA would take the position that the instrument is not a share within the meaning of subsection 51(1). ...

CRA responded: The CRA's position, as stated in Technical Interpretation 2020-0852211C6, remains that, generally, the amount of the dividend designated under the election provided for in subsection 83(2) must be stated on Form T2054 and in the resolution authorizing that election in order for it to be considered valid, regardless of whether the election is filed within the prescribed time limits, or late and accompanied by the payment of the penalty established under subsection 83(4). ...

"Mineral" includes... substances that are considered to be minerals within the ordinary meaning of that word. ... Certain storage rights may be considered a right of entry or user within the meaning of paragraph 162(2)(b) (e.g., storage facilities located in, or immediately adjacent to, an oil or gas field that are for the purposes of storing production from the field before the transfer to transportation or transmission facilities). ...

GAAP determines whether investment fund investees are part of MNE group Rules for investment funds If, applying accounting rules, an investment entity does not consolidate investee companies, then those investee companies should not form part of an MNE group and should not be considered CEs. However, if the accounting rules require that the investment entity consolidates with an investee company, the investee company should be part of an MNE group (where one exists) and should therefore be considered a CE. ...

In such a situation the proceeds will be on account of capital and if there is a reasonable expectation at the time of disposition of the property that the conditions will be met, then the disposition is treated in the ordinary manner, and the original maximum amount is considered to be the sale price of the property. ...

Once such an amount on account of the sale price exceeds the adjusted cost base of the shares (as reduced by any previous such amounts), the excess is considered to be a capital gain that is realized at the time that that amount became determinable, and the adjusted cost base becomes nil. ...