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In finding that X and Y are related, CRA stated (TaxInterpretations translation): Paragraph 252(1)(c) expands the meaning of the term “child” by providing that the child of a spouse or common-law partner of a taxpayer is considered a child of the taxpayer…. ...

24 April 2015 External T.I. 2014-0560401E5- Subsections 15(2) and 227(6.1) and Part XIII tax-- summary under Subsection 227(6.1) Summary Under Tax Topics- Income Tax Act- Section 227- Subsection 227(6.1) repayment of assigned loan to assignee after 2 years In 2013-0482991E5, CRA considered that where Canco seeks to avoid the application of s. 15(2) to a loan (the "Debt") owing to it by a non-resident sister company (Debtco) by assigning the Debt to their non-resident parent (Parentoco) in repayment of a loan owing by it to Parentoco, this assignment will not qualify as a repayment of the Debt (so that s. 214(3)(a) could then apply to impose Part XIII tax on the Debt amount). ...

After the Directorate confirmed that 1999-0009295 (respecting the availability of a reserve under s. 40(1)(a)(iii) to a capital gain under s. 55(2) where the capital gain arose on the receipt of a promissory note that was "considered to have been accepted as evidence of or security for the balance payable of the purchase price of the shares... rather than] as 'absolute payment' of the debt"), and in responding affirmatively, the Directorate stated: [T]he fact that the annual repayment of the balance of sale price was payable at the rate of XXXXXXXX% of the future consolidated annual profits did not cause the Vendor to have the right to demand payment of the balance of the sale price before the end of the taxation year of the Vendor ending on XXXXXXXXXX. ...

. … Based on the limited description…the digital currency would be held outside of Canada and would not be considered to be used or held exclusively in the course of carrying on an active business. ...

., Meyer] would lend support to the position that absent any evidence to the contrary the tax paid to the Japanese tax authorities was voluntary and as such, should not be considered to be a "tax" within the meaning of subsection 126(1). ...

After concluding that Canco would not be entitled to a FTC on the basis inter alia that "a taxable capital gain resulting from a deemed disposition of property is considered to be Canadian-source income, which therefore cannot be included in the foreign non-business income for purposes of claiming a FTC," the Directorate went on to state: Article 21 [of the Canada-Japan Treaty] deems gains of a resident of Canada, which are taxed in Japan under the Convention, to arise from a source in Japan and requires Canada to provide a credit in respect of such Japanese tax against any Canadian tax payable on such gains. ...

For example, some projects could be considered as the installation or improvement of a structure on the surface or sub-surface, the surface being the land or property. ...

It also stated: "We have not considered the application of GAAR to the conversion, but you may wish to consider it further. ...

For any interest paid by CCo to ECo in respect of the Charlie Debts, such interest will be considered to be derived by DCo pursuant to paragraph 6 of Article IV of the Treaty. ...

Indeed, Opco could be considered to have conferred a benefit on Holdco under section 15(1) when the shares were issued. ...