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CRA responded: Although the GAAR Committee considered that [similar] Transactions circumvented the integration principle, it recommended that the GAAR not be applied. ...

CRA commented: Although the GAAR Committee considered that [similar] Transactions circumvented the integration principle, it recommended that the GAAR not be applied. ...

CRA responded: [T]he deposit balances of the non-resident pool participants would be considered “intermediary debts” for the purposes of subparagraphs 18(6)(c)(i) and 212(3.1)(c)(i), with the result that the back-to-back loan rules would be engaged, provided its other conditions are met. ...

CRA confirmed that the new PLOI loan will not cause the old loan to be considered to have been “repaid…otherwise than as part of a series of loans or other transactions and repayments” as per s. 90(8)(a), so that a $10M income inclusion to Canco under the upstream loan rules will be avoided. ...

26 May 2016 IFA Roundtable Q. 7, 2016-0642121C6- 93(2.01) & Capital Contribution-- summary under Subsection 93(2.01) Summary Under Tax Topics- Income Tax Act- Section 93- Subsection 93(2.01) contribution of shares to a subsidiary caused the subsidiary shares to be substituted property CRA considered that the s. 93(2.01) stop loss rule applied where Canco made a contribution of capital to a foreign subsidiary (FA2) of its shares of a non-resident Finco subsidiary (FA1) which had paid dividends out of its deemed active business income to Canco – so that s. 93(2.01) denied a subsequent capital loss realized on an arm’s length sale of the FA2 shares to the extent of such dividends. ...

CRA indicated that De Mond has not altered its view (in 9518515) that a revocable living trust is recognized at the time that legal title to property is transferred to it, with such transfer being considered to occur at fair market value. ...

8 May 2012 Roundtable, 2012-0435771C6- CALU CRA Roundtable – May 2012- Question 10-- summary under Subsection 207.6(2) Summary Under Tax Topics- Excise Tax Act- Section 207.6- Subsection 207.6(2) In response to a question as to the circumstances in which a life insurance policy can "reasonably be considered to be acquired to fund in whole or in part," CRA indicated that the factors it would consider would include: the identity of the employees whose lives are insured as compared to those to be provided benefits under the plan; the timing of the acquisition of the insurance and the setting up of the plan; the timing of the acquisition of the insurance and the setting up of the plan; reasons (other than the existence of the plan) for the employer's purchase of insurance. ...

Is the residence considered to be property that is used principally in the course of an active business (or a farming business) for purposes of the definition of “qualified small business corporation share” (or “share of the capital stock of a family farm or fishing corporation”) in s. 110.6(1)? ...

CRA responded: 2011-0417471E5 dated February 21, 2012…[indicates] that a building is normally considered to be a single property for the purposes of subsection 45(1)…. ...

CRA considered that because, after this change, the use of the single property (the triplex) was still 50% personal and 50% 3 rd-party rental, the change of use rules in s. 45 did not apply. ...