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In such circumstances, the application of subsection 245(2) would also have to be considered. ...

The Tax Court of Canada's reasoning in the RMM Canadian Enterprises Inc. case, referred to above, may support the view that A would not be considered to deal at arm's length with Opco with respect to the acquisition by Opco of the Aco common shares. ...

Finally, the potential application of subsections 55(2) and 245(2) should be considered in any particular situation. 2002-017909 XXXXXXXXXX S. ...

Accordingly, as noted in your letter, if the interest in the family asset which is being disposed of is not a capital property to the disposing spouse, or any of the spouses is not resident in Canada, the subsection 73(1) rollover cannot apply to the transfer, such that the disposition will generally be considered to have occurred at fair market value at the time of the triggering event. ...

Thus, the CEE incurred in 1987 and 1988 would be available to Subscribers under the old rules only in respect of Earned Shares issued upon exercises of Rights that took place during 1986, this being the time that the new agreement in writing would be considered to have been entered into. ...

We are of the view that where individual transactions are posted to subsidiary ledger and not to the general ledger, such subsidiary ledger should generally fall within the ambit of subparagraph 5800(a)(iv) of the Regulations. (3) Accounts and vouchers necessary to verify the information contained in the general ledger or other book of final entry are generally "non-permanent" records and therefore are to be retained for six years from the end of the last taxation year to which the records and books relate pursuant to paragraph 230(4)(b) of the Act. (4) It is a question of fact whether a lease would be considered a special contract or agreement pursuant to subparagraph 5800(a)(v) of the Regulations. ...

(2) Whether a corporate beneficiary receiving an interest in a life insurance policy from a trust as payment of a dividend in kind received by the trust should be considered as having given a consideration for the interest in the life insurance policy? ...

(2) Whether a corporate beneficiary receiving an interest in a life insurance policy from a trust as payment of a dividend in kind received by the trust should be considered as having given a consideration for the interest in the life insurance policy? ...

Yours truly, Kimberley Wharram Manager, Resources Section for Division Director Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 The accelerated investment incentives were announced as part of the Minster of Finance’s 2018 Fall Economic Statement on November 21, 2018. 2 Government assistance and non-government assistance are defined terms in subsection 127(9) of the Act. 3 The specified energy property rules are in subsections 1100(24) to (29) of the Regulations. 4 The relevant “available for use” rules are in subsections 13(26) and 13(27) of the Act. 5 Subsection 127.45(4) deems a taxpayer not to acquire clean technology property before it is considered to have become available for use by the taxpayer, determined without reference to paragraphs 13(27)(c) and 13(28)(d). ...

XXXXXXXXXX Ann Kippen 2024-104569 April 24, 2025 Dear XXXXXXXXXX: Re: Technical interpretation regarding “user” and “online marketplace” for purposes of the digital services tax We are writing in response to your December 2, 2024 and March 6, 2025 letters regarding whether certain suppliers that have digital content available for sale on an intermediary’s digital interface would be considered users of that digital interface based on the definition of “user” in the Digital Services Tax Act (footnote 1) (“DSTA”). ...