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(b) The proceeds received for the disposition of trust property would be considered “property substituted for the property,” for purposes of s. 75(2) and, similarly, if the proceeds were then reinvested in securities, the securities would also be considered substituted property, such that any income or loss from those securities, and any taxable capital gain or allowable capital loss resulting from their disposition, would also be attributed to the settlor. ...

X would only be considered to own the Shares so received from the date of the distribution. Finally, it should be noted that … McNeeley [under appeal] … considered a discretionary trust plan similar to the one in the situation described and concluded that the EBP rules applied. ...

Is the Trust considered to carry on a business where all the property management services are provided by an external manager dealing at arm’s length with it and its beneficiaries? ... Furthermore, CRA here noted that the “Bulletin list[s] the basic services (e.g. heating, parking, laundry room, etc.) that are generally considered to be an inherent part of the rental activity,” but also referred “for example, to cleaning and protective services in respect of rented accommodation” as being additional services that may indicate that “it is possible that the landlord is carrying on a business rather than simply renting out real estate.” ...

(a) of the “resident portion” definition, the amount of the loan owing by the beneficiary would be considered as a contribution by the beneficiary (viewed in this regard as a resident contributor) and would be included in the resident portion. Re (iii), the repayment of the loan would be considered to be a contribution to the trust by the resident beneficiary so that the cash repayment proceeds would be added to the resident portion. ...

1993 December Tax Executive Institute Roundtable, 5-932784-- summary under Subsection 13(27) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(27) "With regard to equipment in the testing stage, it is our opinion that the testing activity would not qualify equipment to be considered 'available for use'. ...

2004 APFF Roundtable Q. 13, 2004-008699-- summary under Subsection 49(1) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(1) Discussion of CRA position that where a lease contains a bargain purchase option, a portion of each rent payment may be considered to be a payment for the right to purchase the property in the future. ...

22 May 2014 May IFA Roundtable, 2014-0526761C6- Foreign affiliate share acquisition or disposition-- summary under Paragraph 95(6)(b) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(6)- Paragraph 95(6)(b) s. 95(6) Committee stats Over the 2010-2013 period a total of 19 cases were considered by the s. 95(6) Committee, which recommended in seven cases that s. 95(6)(b) be applied. ...

30 October 2012 Ontario CTF Roundtable, 2012-0462951C6- Ontario CTF- Penalty Relief-- summary under Subsection 163(1) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(1) The waiving of partial interest within the 10 year limitation period is part of [Voluntary Disclosure Program] policy and is applied to all disclosures that are considered valid by the CRA as a means of encouraging disclosures for older years. ...

LLPs and LLLPs-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Florida and Delaware LLPs and LLLPs treated like LLCs Are Florida and Delaware LLPs and LLLPs that are treated by CRA as corporations considered to come within para. ...

2004 IFA Roundtable Q. 3, 2004-007223-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 Although a partner is not considered to own a specified percentage of the shares of a corporation held by a partnership, a favourable ruling was granted where a corporation issued sufficient voting preferred shares directly to each partner in order to comply with the formal requirements, of the Canada-U.S. ...