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" In responding, CRA stated that in applying proposed Reg. 5907(2.03) in respect of the particular taxation year: any deduction claimed by the affiliate in computing its earnings or loss from that business, in any taxation year of the affiliate that began on or before the commencement of the particular taxation year and for which the earnings or loss from that business had been determined under subparagraph (a)(i) or (ii) of the definition "earnings" in subsection 5907(1) of the Regulations, would be considered to have been actually claimed under the Act and to be within the maximum amount deductible. ...

For example, if Shareholder 4 or his spouse had de facto control of Holdco, the spouse could be considered affiliated with Holdco (by virtue of subparagraph 251.1(1)(b)(i) or (iii) and the definition of "controlled" in subsection 251.1(3)) or to not deal at arm's length with Holdco Q. ...

. … In general, the work is considered temporary if it can reasonably be expected that it does not constitute a continuous employment of more than two years. ...

…[I]f one or other of the equity investments of A and B in Opco were considered to be made as part of a series of transactions in the course of which the dividends were received by Opco and Realtyco… paragraph 55(3.01)(g) would not apply to the increase in interest described in subparagraph 55(3)(a)(v). ...

Will multiple year ends occur as a result and, if so, in which taxation year will the preliminary transactions be considered to occur? ...

Will multiple year ends occur as a result and, if so, in which taxation year will the preliminary transactions be considered to occur? ...

The principal reason for our position is the fact that the Transitional Reserve is temporary and that it could reasonably be considered that, in general, the "qualifying transitional income" on which the Transitional Reserve is based results in an increase in the value of the shares of the capital stock of the corporation. ...

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. ...