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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. ...

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. ...