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CRA stated: [A] partnership would generally be considered a taxpayer for the purposes of the subsection 97(2) rollover and could therefore rely on that subsection to the extent that the conditions set out therein are satisfied. ...

After ruling that the services of the ISO (which were a single supply including payment processing services) were excluded under s. 4(2), CRA stated:...when considered as a whole, the ISO's service is predominantly the transfer, collection or processing of information and/or an administrative service performed by a person who is not at risk (i.e., the ISO does not appear to be financially at risk when it provides assistance to the Merchant such as performing data processing, monthly reports, funds transfer and other support and administrative services). ...

CRA found that s. 17(8)(a)(ii) was not available as the Debt would not be considered to be a loan to the second CFA. ...

. … Under subparagraph 2(a) [of Article X], the S-Corp would be considered to own the shares of Canco owned by the US LLC.... ...

The Directorate indicated that in a recent tax ruling request, the CRA had concluded in light of the foreign law applicable to such a partnership, the provisions of the partnership agreement and the terms and conditions of the loan agreement between the partnership and the U.S. lender that the partners of the partnership were considered to be the payers of the interest on the loan, with the result that such interest was not exempt from withholding tax as the loan did not qualify under s. 212(1)(b)(vii). ...

…[T]aking into consideration the foreign law under which the Partnership was formed, the provisions of the partnership agreement and the terms and conditions of the loan agreement between the Partnership and the U.S. lender, the CRA came to the conclusion that the partners of the Partnership were considered to be the payers of the interest on the Loan. ...

The exemption also will apply where there are taxable sales of butterflied property to an arm's length third party, or taxable sales of investment property from one transferee to another unless the result of the taxable sales is that one or more transferees may reasonably be considered to have been wholly or partially cashed out. ...

CRA responded: An equity-linked investment by an individual such as the one described in your letter is generally considered a prescribed debt obligation pursuant to paragraph 7000(1)(d) of the Regulations such that an amount of interest is calculated pursuant to paragraph 7000(2)(d)…. ...

Before ruling that GAAR would apply respecting transactions intended to avoid the application of the debt forgiveness rules to the non-capital losses of LossCo, rulings were provided that: the operation by AmalCo of the retained branches and the branches to be sold will constitute the carrying on by it of the LossCo business for purposes of s. 111(5)(a)(i); and that the income of AmalCo from the services referred to above "will be considered to be derived from the sale, leasing, rental or development, as the case may be, of similar properties or the rendering of similar services" to the services previously rendered by LossCo. ...

After giving favourable s. 111(5)(a) rulings, CRA ruled that s. 245(2) will apply on the basis "that the repayment of the subordinated debt...will be considered a settlement of the subordinated debt for no consideration for the purposes of applying section 80. ...