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X, could be considered to still be aa affiliated "contributor" to Trust B, as defined in s. 251.1(3), CRA stated (TaxInterpretations translation): [B]ased on… 2014-0534851C6, …when it is necessary to determine if a contributor to a trust is affiliated to the contributor to another trust for purposes of paragraph 251.1(1)(h), a deceased person should be assimilated to the "persons" referred to in subparagraph 251.1(4)(d)(iv). ...

As they did not make the s. 45(2) election, there would be a deemed disposition and reacquisition of the residence at fair market value in 2007; and they will be considered to have commenced to use the property for an income-producing purpose in 2007. ...

Provided these conditions were met in respect of the Plan, it would be considered a pension plan…and the payment received by the beneficiary of the decedent…would constitute a pension benefit…[to] be included in income… pursuant to subparagraph 56(1)(a)(i)… subject to relief available under the Canada-U.S. ...

. … While we have considered the application of subsection 245(2) in respect of the Neuman type income splitting arrangements in the past and have taken the position that GAAR does not apply, we have also specifically stated that this comment regarding the non-application of GAAR relates only to the Neuman case. ...

A would be considered to have disposed of a right, interest or right to dividends in Opco to Mrs. ...

Is the fund considered “specified foreign property,” or is it an “exempt trust”? ...

. … [W]hen a foreign trust grants funds to other organizations…the recipient organization would have to be considered “charitable” according to Canadian common law.... ...

Although the tax may not be paid at the affiliate's year end, provided it is paid in due course when the affiliate's tax return is filed, the tax will be considered paid in respect of the year to which it relates.... ...

CRA responded: Under trust law, capital gains would typically be considered to be part of the capital of a trust; however, a deemed capital gain created under a provision of the Act is a “nothing” for trust purposes. ...

After referencing the position in IT-160R3, para. 9, that a controlling shareholder generally will be considered to have received a benefit qua shareholder where “there is extensive use of the aircraft for personal purposes by the shareholder-employee or … relatives or friends,” CRA stated: [T]he benefit arising from the person's use of the aircraft by the corporation's founder-president should be based on the price of a regular first class ticket for a scheduled flight to the same destination, as the founder-president received the benefit as an employee of the corporation. ...