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1st Scenario In finding that the s. 55(3)(a) exception was not available for the deemed dividends arising in Step 4 under the first Scenario, CRA first indicated (TaxInterpretations translation): Respecting the issuance of shares on an incorporation…prior to the first issuance…the incorporator controls [the corporation] and consequently…he will be considered as being related to that corporation before the first issuance of shares. ... In effect, immediately before the disposition, Holdco would be considered to not be related to Realtyco if the latter did not exist at that moment. ...

1st Scenario In finding that the s. 55(3)(a) exception was not available for the deemed dividends arising in Step 4 under the first Scenario, CRA first indicated (TaxInterpretations translation): Respecting the issuance of shares on an incorporation…prior to the first issuance…the incorporator controls [the corporation] and consequently…he will be considered as being related to that corporation before the first issuance of shares. ... In effect, immediately before the disposition, Holdco would be considered to not be related to Realtyco if the latter did not exist at that moment. ...

If the designation had been made by reference to a precise figure as an eligible dividend without any reference to a redemption of shares or a deemed dividend paid under subsection 84(3), the designation could be considered invalid because it was for a partial dividend. ...

18 June 2015 STEP Roundtable Q. 2, 2015-0572091C6- 2015 STEP – Q2 – Meaning of Graduated Rate Estates-- summary under Graduated Rate Estate Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Graduated Rate Estate one estate even if multiple wills (see also summary of initial response at 19 June 2015 STEP Roundtable, oral Q.2(a)) If an estate for a deceased who passed away after 2015 is under administration in its first 36 months, will it be considered a graduated rate estate in its entirety, even if there are two wills. ...

Since Canco would have been in a position to make the suppression election to deem the dividend to be paid out of pre-acquisition surplus, it is CRA's view that: for the purposes of proposed subsection 90(9) an amount may "reasonably be considered to have been deductible" in respect of the dividend under paragraph 113(1)(d). ...

Would the cash from the dividend be considered substituted property? CRA responded that the estate has not replaced the Holdco shares received on death, so that the cash dividend is not property substituted for the Holdco shares. ...

However, when an employee leaves his or her residence to go to a place other than the employee’s usual place of work or returns from that place to the employee’s residence, this travel will generally be considered as travel in the performance of the duties of his or her office or employment. ...

26 May 2016 IFA Roundtable Q. 3, 2016-0642111C6- PUC of Shares of a FC Reporter-- summary under Canadian Tax Results Summary Under Tax Topics- Income Tax Act- Section 261- Subsection 261(1)- Canadian Tax Results deemed dividend calculation for shareholder not part of Cdn tax results CRA considered that a Canadian corporation (“Issuer”) which has the U.S. dollar as its elected functional currency nonetheless is required to keep track of the paid-up capital of its shares, so that if it issued U.S.$100,000 of shares when the Canadian dollar was at par and redeemed those shares when their Canadian-dollar equivalent was $125,000, there would be a resulting deemed dividend to its shareholder (assuming the shareholder was not a functional currency tax reporter) However, there would be no Part VI.1 tax, as that would relate to the tax results of the corporation rather than its shareholder. ...

However... premiums paid by an individual for a long-term care policy under a "Binding coverage: Residential care" would not be considered premiums paid under a private health services plan and would not qualify as medical expenses giving rise to a non-refundable tax credit. ...

14 September 2017 Roundtable, 2017-0703871C6- CPA Alberta 2017 Q9: PHSP for owner-managers-- summary under Private Health Services Plan Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Private Health Services Plan a self-insured health care spending account (“HCSA”) for a sole employee-shareholder likely will not qualify as a private health services plan Provided that an employee (who is also a shareholder) is active in the business of a corporation whose only employees are also shareholders, and the benefits under the corporation’s private health services plan are reasonable and consistent with the benefits that would be offered to an arm’s length employee performing similar services, would the benefits be considered to be derived from the individual’s employment and in respect of a private health services plan? ...