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After noting that the loan forgiveness would not constitute its repayment for purposes of ss. 90(8) and 90(14), CRA stated: [S]ince Canco will have to include the “specified amount” in respect of the loan in computing its income under subsection 90(6), Canco’s obligation in respect of the loan from FA will be considered an “excluded obligation”…[notwithstanding] that Canco may be able to claim a deduction under subsection 90(9)…so that the debt forgiveness rules will not result in tax implications to Canco. ...

. … In general, supplementary pension benefits are considered to be reasonable when the terms of the supplemental pension plan are substantially the same as those of the IPP. ...

If the returned property is not the original property, the original disposition will not be recognized but the taxpayer will be considered to have disposed of the original property at the time the returned property is transferred to the taxpayer for deemed proceeds of disposition. ...

We have previously concluded that, where employer contributions to a trust established for the benefit of its employees are used to acquire treasury shares of the employer corporation or a corporation related to the employer corporation, the plan or arrangement will be considered to constitute an agreement to sell or issue shares as contemplated by section 7 of the Act. ...

CRA considered that s. 118.1(5.1) does not apply where a GRE donates a capital interest, in a charitable residual trust created by will, to a qualified donee. ...

12 May 2017 External T.I. 2017-0683511E5 F- Purpose tests of a dividend or repurchase of share-- summary under Paragraph 55(3)(a) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3)- Paragraph 55(3)(a) using s. 55(3)(a) to distribute cash otherwise than from safe income likely abusive The CRA position on creditor-proofing suggested that if Opco, which has no safe income and whose common shares have a nominal adjusted cost base and paid-up capital, uses cash (or other assets) to pay a dividend to its shareholder (Holdco) to fund Holdco’s purchase of real property to be rented to it, that cash dividend likely would be considered to have a tainting purpose described in s. 55(2.1)(b)(ii). ...

15 May 2017 External T.I. 2015-0580461E5 F- Life insurance policy held in an RCA trust-- summary under RCA Strip Summary Under Tax Topics- Income Tax Act- Section 207.5- Subsection 207.5(1)- RCA Strip holding of life insurance policy could entail RCA strip CRA considered, respecting an RCA trust with an employee as its sole beneficiary, that its “holding of a life insurance policy with life insurance coverage (death benefit) in a year is a benefit that is conditional on the existence of the RCA” and, thus, was a benefit described in para. ...

After noting the exclusion from “automobile” (and, thus, from the standby charge and operating expense rules) for clearly marked emergency response vehicles, CRA stated: [A]n emergency response vehicle…is generally considered to be clearly identified if it is readily identifiable by the general public as a police or fire vehicle because of symbols or lettering on the exterior of the vehicle. … [I]f … a vehicle that does not meet the definition of automobile, there is still a benefit to the employee under paragraph 6(1)(a) where the vehicle is used for personal purposes. ...

X would be considered to have made a capital contribution to the Trust. ...

After noting that “ T4130 … states that when an employer pays an allowance that is a combination of flat-rate and reasonable per-kilometre allowances that cover the same use for the vehicle, the total combined allowance is a taxable benefit and has to be included in the employee's income,” CRA stated: [P]art of the allowance paid to employees is based on a per kilometre rate that is considered reasonable while the other part of the allowance is not related to the use of the motor vehicle there are two allowances. ...