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Provided that an Electing Partner would not, if his or her ProCorp did not exist, reasonably be regarded as an officer or employee of the Partnership in respect of the provision of Professional Services, the Electing Partner's ProCorp will not be considered to be carrying on a personal services business as defined in subsection 125(7). ...

Rulings The proceeds of the IRA paid to the taxpayer inclusive of the 15% U.S. withholding will be considered to be income from a trust that is sourced in the U.S., and will be included in the taxpayer's income under ss. 104(13)(a) and 12(1)(m). ...

" Ruling "Subject to Comment D below, the Charity's ownership of a XX% interest in the Common Shares in Newco and its representation on the Board of Directors of Newco, in and of themselves, would not be considered activities that would constitute the carrying on of a business that is not a related business of the Charity for the purposes of paragraph 149.1(2)(a). ...

Rulings Including that "the Proposed Transactions, in and by themselves, will not be considered to result in any disposition of property to, or increase in interest by, an unrelated person described in any of subparagraphs 55(3)(a)(i) to (v). ...

Ruling Each of New Farmland 1 and New Farmland 2 will be considered as a replacement property for the Old Farmland. ...

Ruling A former employee of Partnership will be deemed to be a former employee of Sub1 for the purpose of s. 147.2(8) and Partnership will be considered a “predecessor employer” for such purpose, pursuant Reg. 8500(1.2) and the definition of “predecessor employer” in Reg. 8500(1). ...

Comment in Summary: "The issue was considered by the Policy Review Committee and it was decided that it would not be appropriate to extend our long-standing favourable administrative position concerning dividend reinvestment plans of corporations to income distribution reinvestment plans of trusts. ...

2018 Ruling 2018-0752531R3- Public corporation election 89(1)(c)(i)-- summary under Paragraph 4800(2)(a) Summary Under Tax Topics- Income Tax Regulations- Regulation 4800- Subsection 4800(2)- Paragraph 4800(2)(a) Reg. 4800(2)(a)(i) considered to be satisfied when, in fact, none of the shares held by the insiders had ever been listed since the Pubco’s formation by amalgamation Background Pubco was a corporation that was now closely held but was deemed to be a public corporation under s. 87(2)(ii) given that it resulted from the amalgamation of a public corporation and another predecessor. ...

This is also true for the trustee/beneficiary who, in this particular situation, is not considered to have control over the decision to add a new beneficiary. ...

CRA ruled that these transactions will not be considered in themselves to result in a disposition or increase in interest described in any of ss. 55(3)(a)(i) to (v) and, in particular, that the share issuance by Holdco to the Opco shareholders will not be described in s. 55(3)(a)(ii) by virtue of s. 55(3.01)(g). ...