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Moreover… the value of the debt converted (rather than the principal amount) must be considered the amount paid to acquire the shares in determining whether the amount so paid exceeds the fair market value of the shares acquired for the purposes of paragraph 69(1)(a)….. ...

Response: It was intended that the application of s. 17.1(1)(b) would not be limited by the principle of "tracing," so that CRA would not concede that the proceeds of a debt obligation could not reasonably be considered to fund a PLOI simply because those proceeds were deposited into one account while the funds used to directly make the PLOI were withdrawn from another. ...

Although most of the mooted services here instead entailed assistance with activities of daily living, CRA noted that "there may be situations in which a service of assisting a resident with an activity that an average person would often perform on their own may be considered a therapeutic health care service. ...

After ruling that the amounts received by Organizations C from FinanceCo are consideration for a single taxable supply, CRA states: [Organizations C] activities when considered as a whole are predominantly in respect of the promotion and marketing of the Loyalty Program. ...

The following are examples of services that are considered to be in respect of real property for purposes of Part V of Schedule VI: (a) services physically performed on the real property (e.g., construction and maintenance); (b) services that enhance the value of the real property, affect the nature of the real property, relate to preparing the real property for development or redevelopment, affect the management of the real property, or affect the environment within the limits of the real property (e.g., engineering, architectural services, surveying and subdividing, management services, security services); (c) services related to; (i) the transfer or conveyance of the real property or the proposed transfer or conveyance of the real property (e.g., real estate services in relation to the actual or proposed acquisition, lease or rental of the real property, legal services rendered to the owner or beneficiary or potential owner or beneficiary of real property as a result of a will or testament); (ii) a mortgage interest or other security interest in the real property; or (iii) the determination of the title to the real property. ...

…[I]f for example,… a manufacturing company charged a fee for providing a loan to its customers, such a fee would be considered to be a separate fee or charge for a financial service Partnerships included 15. ...

Where the formal dissolution of a corporation is not complete but there is substantial evidence that the corporation will be dissolved within a short period of time, for the purpose of subsections 88(1) and (2) the corporation is considered to have been wound up. ...

CRA responded: Forco's issuance of shares…would result in Forco being considered to have "sold an investment in itself"…. ...

Since the management company has operational control, the management company would be considered to be a participant and operator of the joint venture…. ...

Every combination of eligible corporations or eligible Canadian partnerships whose names appear in Part A of the form (and on any attached page) is considered to have made the election. ...