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C) a) The issue is not whether any portion of the amount owed by the non-resident person under paragraph 17(2)(a) (the "second loan") may reasonably be considered to relate to a loan or transfer of property described in subparagraph 17(2)(b)(i) (the "first loan"), but, rather, whether it is reasonable to conclude that the foreign affiliate entered into the second loan because of the first loan. ...

For an amount to be considered "as a payment out of or under a RRIF" for the purposes of the definition of "pension income" in subsection 118(7), a payment shall arise from the performance of an agreement between the RRIF carrier and the annuitant and delivered in satisfaction of an obligation. ...

Similarly, a notice in an annual or quarterly report that an eligible dividend has been paid is considered valid for that quarter. ...

Furthermore, if Parentco had acquired Targetco shares prior to the amalgamation from the former shareholders of Targetco, the application of rollover provisions such as subsection 85(1) or 85.1(1) would have to be considered to avoid a taxable event for the vendors.) ...

Whether the CRA can confirm that the interest income earned by the trust on the Excluded Debt, distributed to a beneficiary who is a specified individual and included in his/her income under 104(13) would be considered to be split income? ...

PRINCIPALES QUESTIONS: Whether losses realized by a subsidiary have to be considered in computing the consolidated safe income of a parent corporation. ...

8 July 2020 CALU Roundtable Q. 2, 2020-0842141C6- Return of premiums on death & CDA Unedited CRA Tags 89(1) "capital dividend account", 148(9) "disposition" Principal Issues: Whether or not a payment under a particular life insurance policy would be considered proceeds of a life insurance policy in consequence of death for purposes of the definition of “capital dividend account” in subsection 89(1) of the Act. ...

The terms and conditions of the shared ownership arrangement, the specific life insurance contract and all other related agreements which may form part of the particular arrangement and the particular facts at the given time would have to be considered in the determination of the FMV of Opco’s interest in the life insurance policy. ...

In particular, is the gain considered to be from a source in Australia for purposes of computing the foreign tax credit? ...

However, the deeming rules described above do not apply unless a number of conditions are met, including that: The amount is designated by the trust, in respect of the beneficiary, in the trust’s return of income under Part I for the particular taxation year; The amount may reasonably be considered (having regard to all the circumstances including the terms and conditions of the trust) to be part of the amount that was included in computing the income for that taxation year of the beneficiary because of: o an amount payable under paragraph 104(13)(a), o an amount upon which the trust and the beneficiary have made a preferred beneficiary election under subsection 104(14), or o a benefit under section 105 conferred upon a beneficiary by the trust; The taxpayer is in the particular taxation year a beneficiary under the trust; The trust is, throughout the particular taxation year, resident in Canada; and The total of all amounts each of which is an amount designated, under subsection 104(19), by the trust in respect of a beneficiary under the trust in the trust’s return of income under Part I for the particular taxation year is not greater than the total of all amounts each of which is the amount of a taxable dividend, received by the trust in the particular taxation year, on a share of the capital stock of a taxable Canadian corporation. ...