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

…[T]he determination of the nature of the contractual relationship between the Employer and the Leasing Corporation is one of fact and law to be considered by the parties. ...

In connection with the s. 55(3.1)(b)(i)(A)(II) rule, CRA indicated that indebtedness of Foreign SpinCo will be considered to reduce the FMV of each property of Foreign SpinCo pro rata in proportion to the relative FMV of all property of Foreign SpinCo. ...

Consequently, LP would not be considered to be a "foreign affiliate" of Canco 3 and Forco's interest in LP would not qualify as "excluded property"…. ...

2 April 2014 External T.I. 2012-0473151E5 F- Limitation du coût de location d'un véhicule-- summary under Section 67.3 Summary Under Tax Topics- Income Tax Act- Section 67.3 GST ITCs included under element E of formula Are amounts of recovered GST and QST respecting the lease of a vehicle to be considered in element E in ss. 67.3(c) and (d)? ...

2 April 2014 External T.I. 2012-0473151E5 F- Limitation du coût de location d'un véhicule-- summary under Subsection 248(16) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(16) GST ITCs constitute a “reimbursement” for car lease expense limitation purposes Are amounts of recovered GST and QST respecting the lease of a vehicle to be considered “reimbursements” under element E in ss. 67.3(c) and (d)? ...

Would the Taxpayer and the Other Person can be considered common-law partners in Canada? ...

Would the Taxpayer be considered a resident of Canada given his close ties? ...

In responding affirmatively, CRA stated: If the interest expense is not deductible by Borrower FA in any taxation year under the relevant foreign country's income tax law, it will nevertheless be deductible…pursuant to paragraph 5907(2)(j)… because it will be considered to have been made or incurred by Borrower FA for the purpose of gaining or producing earnings from an active business carried on by it as determined under subparagraphs (a)(i) or (ii) of the definition of "earnings" in subsection 5907(1)…. ...

In responding affirmatively, CRA stated: If the interest expense is not deductible by Borrower FA in any taxation year under the relevant foreign country's income tax law, it will nevertheless be deductible…pursuant to paragraph 5907(2)(j)… because it will be considered to have been made or incurred by Borrower FA for the purpose of gaining or producing earnings from an active business carried on by it as determined under subparagraphs (a)(i) or (ii) of the definition of "earnings" in subsection 5907(1)…. ...