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Paragraph 187 of the Commentary to new Article 29 sets out examples of treaty-shopping strategies commonly referred to as “conduit arrangements”, as well as arrangements that should not be considered to be conduit arrangements. ...

Subsection 55(2) read as follows prior to the amendment introduced in Bill C-15: (2) Where a corporation resident in Canada has received a taxable dividend in respect of which it is entitled to a deduction under subsection 112(1) or (2) or 138(6) as part of a transaction or event or a series of transactions or events, one of the purposes of which … was to effect a significant reduction in the portion of the capital gain that, but for the dividend, would have been realized on a disposition at fair market value of any share of capital stock immediately before the dividend and that could reasonably be considered to be attributable to anything other than income earned or realized by any corporation after 1971 and before the safe-income determination time for the transaction, event or series, notwithstanding any other section of this Act, the amount of the dividend … (a) shall be deemed not to be a dividend received by the corporation; (b) … (c) where a corporation has not disposed of the share, shall be deemed to be a gain of the corporation for the year in which the dividend was received from the disposition of a capital property. ...

2) if yes, is this property considered to be used principally in the course of carrying on a farming business? ...

X being considered not dealing at arm's length with Acquéreurco for purposes of section 84.1. ...

Raisons: Although subsection 146(8.2) requires, inter alia, that the annuitant receives a payment from an RRSP, the CRA generally accepts that an amount deemed received as a benefit out of or under an RRSP pursuant to subsection 146(8.8) be considered as a payment received from an RRSP for the purposes of subsection 146(8.2). ...

It further states that the six examples in paragraph 187 of the OECD Commentary on Article 29 should also be considered when determining whether the “principal purpose test” would apply in the case of conduit arrangements. ...

The Court recognized the three basic criteria of (i) scientific or technological advancement,(ii) scientific or technological uncertainty and (iii) scientific and technical content described in the Circular and required in respect of a project in order for it to be considered SR&ED. ...

5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 10, 2018-0761551C6 F- Attribution rules and promissory note Unedited CRA Tags 74.5(2) Principales Questions: Whether issuance of a promissory note may be considered as a payment of accrued interest for the purposes of subparagraphs 74.5(1)b)(ii) and (iii) and paragraphs 74.5(2)(b) and (c)? ...

It is therefore our opinion that the deemed ownership of a property is not to be considered in the interpretation of paragraph 88(1)(b) and 88(1)(d)(i) of the ITA. ...

CRA Response: The Legislative Proposals in respect of Non-Resident Trusts and Foreign Investment Entities, most recently released by the Department of Finance in October 2003, propose to implement certain provisions of the budget tabled in Parliament on February 16, 1999 and significantly amend the rules relating to the taxation of trusts that are not otherwise considered resident in Canada. ...