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CRA indicated that it was not prepared to extend its policy on farm-in arrangements to this situation (given that “carrying out the work on the claims does not give a right in the claims but potentially only an option to acquire them”), stating: Consequently … the amounts paid to carry out the work on the claims of Corporation B would be added to the cash payments provided for in the agreement and would be considered part of the overall consideration given by Corporation A to acquire a property. ...

28 April 2010 External T.I. 2009-0347581E5 F- Frais de formation-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose expense incurred in course of operating real property need not have a direct effect on profit When asked whether expenses for attending a convention, seminar, luncheon meeting or other meeting incurred by an individual in the course of operating a business or an immovable are deductible under s. 9 even where there is no direct effect on profits, CRA stated: [I]n order for an expense to be considered to be made or incurred "for the purpose of", it is not necessary to show that income actually resulted from the particular outlay or expenditure itself. ...

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

(c) of variable A of the formula, for its 2004 taxation year, CRA stated: [S]ince DEFco received from ABCco, during the period 2001 to 2005, a portion ($800,000) of the total taxable dividends paid by ABCco ($900,000), the portion of the dividend received by DEFco that can reasonably be considered to be attributable to an amount described in paragraph (a), (b) or (c) of the description of A in respect of ABCco should be prorated based on the taxable dividends received by DEFco out of the total taxable dividends paid by ABCco. ...

These factors should be considered in light of the purpose of section 84.1, which is to prevent the withdrawal of corporate surpluses as a tax-free return of capital by way of a non-arm's length transfer of shares and through the use of the capital gains deduction. ...

29 January 2018 External T.I. 2017-0682301E5- Deemed Distribution and Withdrawal from IRA-- summary under Clause 56(1)(a)(i)(C.1) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(a)- Subparagraph 56(1)(a)(i)- Clause 56(1)(a)(i)(C.1) the deemed U.S. income inclusion from an IRA on renouncing U.S. citizenship or relinquishing a green card also is recognized for ITA purposes The Taxpayer, a Canadian citizen, was considered under the Code to be a U.S. long term resident and to have received a taxable distribution of her entire interest in her IRA the day before she relinquished her green card. ...

CCRA indicated that although s. 40(3.4) would apply, under its administrative position, only 1/2 of the taxpayer's loss would be considered to be nil under s. 40(3.4)(a) under the formula: Deemed nil loss = (the lesser of S, P and B) / S x L where S = the number of shares disposed of at that time 100 P = the number of shares acquired during the period described in paragraph 40(3.3)(b) 50 B = the number of shares remaining at the end of that period 50 L = the loss on the disposition otherwise determined And therefore: Deemed nil loss = 50 / 100 x L CCRA indicated that s. 40(3.4) would apply to the entire loss arising under a second variation, under which, on June 1, 200X, the taxpayer disposed of 50 of the 100 Pubco common shares and on June 2, 200X, acquired an additional 50 Pubco common shares of Pubco. ...

Can the minor child be considered, in these Scenarios, to have sole beneficial interest in the amounts payable under the annuity as required by s. 60(l)(ii)(B) as it was proposed to be amended [which stipulated that the annuity be one "under which the taxpayer, or a trust under which the taxpayer is the sole person beneficially interested in amounts payable under the annuity, is the annuitant …"]? ...

An affiliated employer does not include a person who would not otherwise be related or considered affiliated with another person but for the definition of "person related to the employer" in section 60(j.1)(iv). ...

Therefore, book debts that have been reduced by outstanding cheques on the date of the end of a fiscal period cannot be considered to have been paid on that date for the purposes of the tax under Part I.3 of the Act. ...