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CRA went on to state: Where in a particular year, more than 50% of a particular property is being used for some purpose other than farming or fishing or is otherwise vacant or idle, generally speaking, such non-farming or fishing use would result in the entire property not being considered as being used principally in the business of farming or fishing in Canada for the year. ...

7 March 2022 External T.I. 2021-0895571E5- Clarification of Comments in 2020-086483-- summary under Paragraph (k) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement- Paragraph (k) 3 years may start counting from before the grant year/ unfavourable counting where employer has non-calendar year 2020-0864831I7 found that full-value restricted share units (“RSUs”) granted early in the calendar taxation year of the employer (the “Grant Year”) were considered to be in respect of services in the previous year, so that such award came within the salary deferral arrangement (SDA) definition, and would not be excluded under para. ...

Although the Directorate indicated that one possible interpretation would require the associated CCPCs to convert each component of their TCEC computation (which the Directorate noted “would be administratively burdensome, especially when the associated corporations could not rely on subsection 261(7)”), the Directorate concluded: The day the TCEC of the associated corporation is considered to “arise” for the purposes of determining the conversion rate according to paragraph 261(5)(c) is the last day of the taxation year of the associated corporation for which it is computed because that is the day when the amount of the TCEC is determined pursuant to section 181.2 (hence when an amount relevant to computing the Taxpayer’s Canadian tax results is created). ...

Respecting who are the objects of the test provided in subsection 74.4(2), which refers to where it may reasonably be considered that where one of the main reasons for a transfer or a loan of property to a corporation may be to reduce the income of the transferor and to benefit a designated person in respect of the individual, we are of the view that a designated person in respect of Trust A would include, in this situation, a person under 18 years who would be beneficially interested in Trust A if subsection 248(25) applied without taking into account clauses (b)(iii)(A)(II) to (IV), or a person under 18 years who did not deal at arm's length with a person who would be beneficially interested in Trust A if subsection 248(25) applied without taking into account clauses (b)(iii)(A)(II) to (IV). ...

After quoting 9725615 as to the meaning of "significant," CRA noted that an "increase in interest of only a small percentage ["faible pourcentage"] could be considered by the CRA not to be significant. ...

Respecting s. 191(3)(b), CRA noted that although Corporation acquired the Class C shares, it could not be considered to have a substantial interest in itself and, conversely, it acquired those shares from a person (Trust) who already had a substantial interest in Corporation. ...

X would not be considered, for purposes of subsection 74.4(2), to have transferred, directly or indirectly, property to Holdco. ...

22 January 2016 External T.I. 2015-0617601E5 F- Pipeline followed by butterfly-- summary under Paragraph 55(3.1)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(3.1)- Paragraph 55(3.1)(b) where pipeline transaction followed by split-up butterfly, the opco also is a distributing corporation CRA considered transactions in which, during the second year of conventional pipeline transactions, the Newco ("Corporation 2") was split between the estate beneficiaries under a butterfly reorg: The shares of the opco (“Corporation 1”), whose ACB was stepped up on death, are sold by the estate to its newly-incorporated Corporation 2 for high-PUC prefs (rather than the more usual note); after the wind-up of Corporation 2 into Corporation 1 a year later under s. 88(1), the shares (both common and pref) of Corporation 1 are distributed to the two beneficiaries; two months later, there is a split-up butterfly of Corporation 2 between the two newcos (Corporations 3 and 4) of the two beneficiaries, so that Corporations 3 and 4 between them continue to carry on the business which previously was carried on by Corporations 1 and 2. ...

The general rate income pool at the end of the year is $60,000, so that Canco is considered to have made an excessive eligible dividend designation (“EEDD”), as defined in s. 89(1), of $10,000 in respect of each eligible dividend paid. ...

CRA now considered an example of a private-corporation employer, which in addition to establishing a defined benefit registered pension plan (RPP) for all of its employees, also established a trusteed defined benefit supplementary pension plan (an RCA) for several key owner-managers, and which purchased exempt life insurance policies on the life of certain (but not all) plan members, and with the employer contributions (after the RCA refundable tax) being used both to fund the mortality charges and to accumulate cash within the policy. ...