Subsection 15(1)

Cases

Laliberté v. Canada, 2020 FCA 97

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Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) the Cirque du Soleil’s bearing most of the $41.8M cost of a space trip for its controlling shareholder gave rise to a shareholder benefit 267
Tax Topics - General Concepts - Onus Tax Court could determine a taxable benefit percentage (different from that assumed by the Minister) based on all the evidence 304

Babich v. Canada, 2013 DTC 5010 [at 5556], 2012 FCA 276, aff'g 2010 TCC 352

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The Queen v. Robinson, 2000 DTC 6176 (FCTD)

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Canada v. Chopp, 98 DTC 6014 (FCA)

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The Queen v. Fingold, 97 DTC 5449 (FCA)

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Hrga v. The Queen, 97 DTC 5165 (FCTD)

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Toma v. The Queen, 95 DTC 5356 (FCTD)

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Penny v. The Queen, 95 DTC 5083 (FCTD)

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Cartwright v. The Queen, 94 DTC 6677 (FCTD)

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Winter v. The Queen, 90 DTC 6681 (FCA)

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Tax Topics - Income Tax Act - Section 245 - Subsection 245(2) specific provisions applied before GAAR 96
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) 163

Youngman v. The Queen, 90 DTC 6322 (FCA)

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Tax Topics - General Concepts - Onus 83

Vine Estate v. The Queen, 89 DTC 5528 (FCTD)

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Friedland v. The Queen, 89 DTC 5341 (FCTD)

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Grohne v. The Queen, 89 DTC 5220 (FCTD)

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Cooper v. The Queen, 88 DTC 6525, [1989] 1 CTC 66 (FCTD)

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Tax Topics - General Concepts - Illegality income tax consequences attaching to illegal loan 75
Tax Topics - Income Tax Act - 101-110 - Section 105 - Subsection 105(1) interest-free loan recognized as obligation rather than benefit 101

R. v. Century 21 Ramos Realty Inc., 87 DTC 5158, [1987] 1 CTC 340 (Ont.C.A.)

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Hall v. The Queen, 86 DTC 6208, [1986] 1 CTC 399 (FCTD)

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Indalex Ltd. v. The Queen, 86 DTC 6039, [1986] 1 CTC 219 (FCTD), aff'd 88 DTC 6053, [1988] 1 CTC 60 (FCA)

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shareholder

Murphy v. The Queen, 85 DTC 5462, [1985] 2 CTC 248 (FCTD)

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The Queen v. Houle, 83 DTC 5430, [1983] CTC 406 (FCTD)

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Tax Topics - General Concepts - Tax Avoidance 28

Schlamp v. The Queen, 82 DTC 6274, [1982] CTC 304 (FCTD)

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The Queen v. Schubert, 80 DTC 6366, [1980] CTC 497 (FCTD)

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Tax Topics - General Concepts - Fair Market Value - Other 34

Berbynuk v. The Queen, 78 DTC 6322, [1978] CTC 448 (FCTD)

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Perrault v. The Queen, 78 DTC 6272, [1978] CTC 395 (FCA)

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The Queen v. Ginter, 77 DTC 5274, [1977] CTC 418 (FCA)

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Steeves v. The Queen, 76 DTC 6269, [1976] CTC 470 (FCTD)

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The Queen v. Phillips, 76 DTC 6093, [1976] CTC 126 (FCA)

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Rosenblat v. The Queen, 75 DTC 5274, [1975] CTC 472 (FCTD)

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The Queen v. Neudorf, 75 DTC 5213, [1975] CTC 192 (FCTD)

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The Queen v. Leslie, 75 DTC 5086, [1975] CTC 155 (FCTD)

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) 95

Huron Steel Fabricators (London) Ltd. v. M.N.R., 75 DTC 5006, [1974] CTC 889 (FCTD)

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Tax Topics - General Concepts - Fair Market Value - Shares 32

Angle v. M.N.R., 74 DTC 6278, [1975] 2 S.C.R. 248

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Tax Topics - General Concepts - Res Judicata 160

Byke Estate v. The Queen, 74 DTC 6585, [1974] CTC 763 (FCTD)

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Bernstein v. MNR, 74 DTC 6041, [1974] CTC 4 (FCTD), aff'd 77 DTC 5187, [1977] CTC 328 (FCA)

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Kennedy v. MNR, 73 DTC 5359, [1973] CTC 437 (FCA)

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MNR v. Bisson, 72 DTC 6374 (FCTD)

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Guilder News Co. (1963) Ltd. v. MNR, 73 DTC 5048, [1973] CTC 1 (FCA)

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MNR v. Pillsbury Holdings Ltd., 64 DTC 5184 (Ex Ct)

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confer

See Also

Pelletier v. Agence du revenu du Québec, 2021 QCCQ 670 (Court of Quebec)

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Tax Topics - Excise Tax Act - Section 173 - Subsection 173(1) the net tax addition for the shareholder benefit from personal use of a corporate helicopter should reflect GAAP depreciation rather than (ITA) depreciable-property class rates 213

Spiegel Sohmer Inc. v. Agence du revenu du Québec, 2021 QCCQ 69

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose reimbursing expenses for the wedding of a law firm partner’s daughter were non-deductible to the firm management company 192

Wise v. The Queen, 2019 TCC 196

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Tax Topics - General Concepts - Effective Date subsequent year’s transactions following a s. 15(1) assessment had no retrospective effect 221

Kyard Capital 2007 Inc. v. Agence du revenu du Québec, 2019 QCCQ 1617

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) payment of professional dues was benefit 140
Tax Topics - Income Tax Act - Section 232 - Subsection 232(1) - Solicitor-Client Privilege unnecessary to waive privilege in order to substantiate the nature of legal services provided 133

Mikhail v. The Queen, 2019 TCC 49 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) failure to properly account for near-cash rebates was neglect under s. 152(4)(a)(i) 154

Laliberté v. The Queen, 2018 TCC 186

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Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) taxable benefit from one company initially bearing costs of shareholder space trip and then being reimbursed by an Opco 218

Melançon v. The Queen, 2018 TCC 73

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Tax Topics - General Concepts - Effective Date rebooking of “expense” as shareholder advance was retroactive tax planning 174

Rowntree v Commissioner of Taxation, [2018] FCA 182

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Tax Topics - General Concepts - Evidence contract must be evinced by documents or conduct 160
Tax Topics - General Concepts - Evidence contract must be evinced by documents or conduct

Engelberg v. Agence du revenu du Québec, 2017 QCCQ 14819

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R. v. Golini, 2016 TCC 174

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Tax Topics - General Concepts - Sham sham doctrine did not apply to a "minor pretence" 338
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) interest deduction on limited recourse loan 305
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) use of corporate asset to create PUC was abuse of s. 84(1) 250
Tax Topics - Income Tax Act - Section 84 - Subsection 84(1) policy of 84(1) 219

Latham v. The Queen, 2015 DTC 1104 [at 617], 2015 TCC 75

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Tax Topics - Income Tax Act - Section 84 - Subsection 84(2) deemed dividend not possible where foreclosure eliminated corporations's assets

Charania v. The Queen, 2015 DTC 1103 [at 614], 2015 TCC 80 (Informal Procedure)

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Tax Topics - General Concepts - Effective Date consideration for transfer to shareholder adjusted without price adjustment clause 242

Rogers Estate v. The Queen, 2015 DTC 1029 [at 124], 2014 TCC 348

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Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) capital gain can arise from property which is not capital property 271
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) exercise of stock option surrender plan for FMV was not "remuneration" 121
Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(a) s. 7 a complete code for taxation of stock option benefits 230
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Options holding one's employee stock options until just before they expire is not typical of an adventure in the nature of trade 185

Versteegh Ltd & Ors v. Commissioners, [2013] UKFTT 642 (TC)

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business taxable share interest on loan held by affiliate 158

Tyskerud v. The Queen, 2012 DTC 1179 [at 3453], 2012 TCC 196 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) obvious and substantial shareholder benefit 58

McIntosh v. The Queen, 2012 DTC 1049 [at 2741], 2011 TCC 579 (Informal Procedure)

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Canadian Winesecrets Inc. v. The Queen, 2011 DTC 1310 [at 1742], 2011 TCC 390 (Informal Procedure)

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Tax Topics - General Concepts - Fair Market Value - Other 168

Boulet v. The Queen, 2010 DTC 1015 [at 2602], 2009 TCC 261

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Tax Topics - General Concepts - Fair Market Value - Land binding NAL agreement suppressed land's FMV 217
Tax Topics - Income Tax Act - Section 54 - Principal Residence basement apartment was separate from principal residence 63

Potvin v. The Queen, 2008 DTC 4813, 2008 TCC 319 (Informal Procedure)

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Gestion Léon Gagnon Inc. c. La Reine, 2007 DTC 267, 2006 TCC 682

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Park Haven Designs Inc. v. The Quenn, 2006 TCC 685

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Truckbase Corporation v. The Queen, 2006 DTC 2930, 2006 TCC 215 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees shareholder agreement expenses deductible 101

Colubriale c. La Reine, 2006 DTC 2577, 2004 TCC 578

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Tax Topics - General Concepts - Fair Market Value - Land 129

Roth v. The Queen, 2005 DTC 1570, 2005 TCC 484, aff'd 2007 DTC 5222, 2007 FCA 38

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense purported transfer of knowhow to corportion did not entail acquisition of property 98
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property knowhow not propery 85

World Corp. v. The Queen, 2003 DTC 951, 2003 TCC 494

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Dobbin v. The Queen, 2003 DTC 118 (TCC)

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Foresbec Inc. v. The Queen, 2002 DTC 1786 (TCC), aff'd 2003 DTC 5455, 2002 FCA 186

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Tax Topics - General Concepts - Sham documents did not reflect legal reality 58
Tax Topics - General Concepts - Tax Avoidance documents did not reflect legal reality 58
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose 81

Robson v. The Queen, 2001 DTC 1039 (TCC)

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Davisson v. The Queen, 2000 DTC 2140 (TCC)

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Safety Boss Ltd. v. The Queen, 2000 DTC 1767 (TCC)

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Pellizzari v. MNR, 87 DTC 56 (TCC)

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Long v. The Queen, 98 DTC 1420 (TCC)

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Donovan v. The Queen, 94 DTC 1143 (TCC), aff'd 96 DTC 6085 (FCA)

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) imputed interest income under barter exchange would arise to extent that an interest-free loan to a corporation would have reduced the s. 15(1) benefit 227

Dale v. The Queen, 94 DTC 1100 (TCC), aff'd supra.

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) shares must be issued within a reasonable time 220
Tax Topics - Statutory Interpretation - Drafting Style 85

Del Grande v. The Queen, 93 DTC 133 (TCC)

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Simpson v. MNR, 92 DTC 1912 (TCC)

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Mullen v. MNR, 90 DTC 1551 (TCC)

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Doyon v. MNR, 90 DTC 1132 (TCC)

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Gendron v. MNR, 89 DTC 582 (TCC)

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President of India v. La Pintada Companid Navigacion S.A., [1985] A.C. 104

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Cangro Resources Ltd. v. MNR, 67 DTC 582 (TAB)

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend distributions out of share premium based on number of shares held were dividends 211
Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) distributions out of share premium based on number of shares held were dividends 211

Administrative Policy

13 November 2020 Internal T.I. 2020-0864831I7 - Equity award plan and recharge agreement

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangement - Paragraph (k) para. (k) not available where RSUs are granted early in Year 1 and vest 36 months later 179
Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) s. 7(3)(b) did not apply to recharge agreement reimbursements made to a parent that had the discretion to settle the RSUs in cash 293
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) no agreement to issue shares under an RSU if the company can choose to settle in cash 139

19 November 2009 External T.I. 2007-0257251E5 F - Assurance-vie

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Tax Topics - Income Tax Act - Section 148 - Subsection 148(9) - Disposition - Paragraph (d) disposition by operation of law if there is a new contract 162
Tax Topics - Income Tax Act - Section 148 - Subsection 148(10) - Paragraph 148(10)(d) designation of a different beneficiary does not entail a disposition 132
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (d) CDA addition to beneficiary not reduced by ACB of policy to the different policyholder - but s. 246(1) or 245(2) germane 195

2019 Ruling 2018-0762581R3 - Foreign Affiliate Reorganization

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Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(2) - Paragraph 5907(2)(f) Reg. 5907(2)(f) does not apply where inventory is transferred on a foreign rollover basis 361
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(2.1) Reg. 5907(5.1) applicable to pre-wind-up transfer on a foreign tax law rollover basis 155

5 October 2018 APFF Roundtable Q. 14, 2018-0768851C6 F - Avantage imposable découlant de l’utilisation d’un aéronef

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AD-18-01: Taxable Benefit for the Personal Use of an Aircraft

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) 656
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) non-deductibility where personal use of corporate aircraft by shareholders 120

May 2017 CPA Alberta Roundtable, ITA Q.9

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Private Health Services Plan private health service plan rules generally are not available for a sole shareholder-employee 180
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) HCSA for sole shareholder-employee unlikely to operate as insurance plan 200

May 2016 Alberta CPA Roundtable, Q.15

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Tax Topics - Income Tax Act - Section 67 deduction by corporation of rents/reimbursements paid for use of office in shareholder’s home 192

2016 Ruling 2016-0630761R3 - Transfer of Shares

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Tax Topics - Income Tax Act - Section 93 - Subsection 93(1.11) transfer of an FA with exempt earnings by FA Holdco to Can Subco required to occur at less than the shares’ FMV 548
Tax Topics - Income Tax Regulations - Regulation 5901 - Subsection 5901(2) - Paragraph 5901(2)(b) stated capital distribution from FA treated as pre-acq dividend 188

7 October 2016 APFF Financial Strategies and Instruments Roundtable Q. 1, 2016-0651771C6 F - Critical Illness Insurance

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14 March 2016 External T.I. 2016-0626781E5 - Neuman Type Situation

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) s. 56(2) likely non-applicable where spouse subscribes nominal consideration for Opco shares and receives a large discretionary dividend 262
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) Kieboom treated as entailing disposition of right to receive dividends 340
Tax Topics - Income Tax Act - Section 73 - Subsection 73(1) spousal rollover for Kieboom disposition of economic interest 82

9 October 2015 APFF Roundtable Q. 4, 2015-0595541C6 F - Computation of taxable benefit

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7 October 2016 APFF Roundtable, Q.8

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) policy on employees’ purchases of discounted merchandise excludes condos 155

9 October 2015 APFF Roundtable Q. 13, 2015-0595781C6 F - Reimbursement of attributed income

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Tax Topics - Income Tax Act - 101-110 - Section 103 - Subsection 103(1.1) no secondary adjustments are required for the operation of most income attribution provisions 117

S2-F1-C1 - Health and Welfare Trusts

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29 April 2015 External T.I. 2014-0532691E5 F - Vente – immeuble - syndicat copropriétaire

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation community of condominium owners is treated by the Civil Code as a legal person, and is a corporation 125
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) a syndicate of condominium co-owners could qualify as a s. 149(1)(l) corporation, so that a capital gain realized by it on a condo sale would be exempt 151

3 March 2015 Internal T.I. 2014-0527841I7 F - Avantage imposable pour aéronef

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(c) apportionment of aircraft use between business and personal 74
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.4) - Paragraph 15(1.4)(c) s. 15(1.4)(c) applied to extend scope of Massicotte indirect benefit doctrine 170
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) s. 15(1.4)(c) applied to extend scope of Massicotte indirect benefit doctrine 857

24 September 2014 External T.I. 2014-0522261E5 - Shareholder benefit on leasehold improvements

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7 August 2014 External T.I. 2014-0528841E5 F - Changement à une résidence principale

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Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(c) addition of a door to an exterior wall could be considered a structural change triggering a change of use 136
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(5) Reg. 1102(5) not applicable where door added by tenant to basement rental property 181

11 March 2014 Internal T.I. 2013-0513221I7 F - Stock options

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) s. 56(2) benefit where corporation implicitly consented to consultant's options being issued by client directly to its shareholder 170
Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) implicit transfer by corporation when stock options earned by it were issued directly by its client to its shareholder 175
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) s. 248(28) does not prevent a double income inclusion to corporation under s. 56 and shareholder under s. 15 226
Tax Topics - Income Tax Act - Section 9 - Timing no s. 9(1) income inclusion from consultant being granted stock options until exercise 226
Tax Topics - General Concepts - Fair Market Value - Options stock options with no in-the-money value could have nil FMV 134
Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) s. 15 benefit due to shareholder receipt of stock options earned by corporation added to the ACB of the exercised shares 165

24 April 2012 Internal T.I. 2011-0400671I7 F - Honoraires professionnels

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benefit
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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs fees incurred by individual before intention to form a corp did not qualify as pre-incorporation expenses 465
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) tax planning fees paid to joint counsel qualified as a disposition expense 137

16 April 2012 External T.I. 2011-0411491E5 - Taxation of distributions of a US LLC

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Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) taxable benefit where US taxes on LLC income allocated to indirect Cdn member are paid by LLC or intermediate ULC 161

7 November 2013 External T.I. 2013-0473771E5 - Shareholder of a Not-for-profit corporation

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder NPO member receiving "shareholder" benefit 55

1 May 2013 Internal T.I. 2009-0321721I7 - Stock Option Recharge on Grant Date

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Tax Topics - General Concepts - Fair Market Value - Options use of Black-Scholes 142

4 December 2013 External T.I. 2012-0465891E5 F - Primes d'assurance / Premiums

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) sub plan with only one employee of particular employer could be a group plan if benefits similar to those for employees in other sub plans 172

29 April 2013 External T.I. 2010-0356401E5 - Stock Option Recharge on Grant Date

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19 May 2010 External T.I. 2010-0364131E5 F - Issuance - Discretionary shares

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Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) Kieboom/s. 69(1)(b) rather than s. 15(1) where benefit conferred by shareholder rather than corporation 185
Tax Topics - Income Tax Act - Section 74.1 - Subsection 74.1(1) application of Kiebom to consider interest in corp to have been transferred to spouse could engage s. 74.1(1) 221

2012 Ruling 2010-0391281R3 - Incentive Plan - Reimbursement Agreement

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5 October 2012 APFF Roundtable Q. 13, 2012-0454181C6 F - Discretionary Dividend Shares

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Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) general policy against conferring a benefit on a corporation 205
Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(7) - Paragraph 110.6(7)(b) acquisition by Holdco of discretionary dividend shares of Opco at undervalue could engage s. 110.6(7) application to Opco commons 208

8 May 2012 CALU Roundtable Q. 7, 2012-0435661C6 - Shareholder Benefit - Co-Ownership Life Insurance

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23 January 2012 External T.I. 2011-0409671E5 F - Propriété superficiaire

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Tax Topics - Income Tax Act - Section 54 - Principal Residence - Paragraph (e) land leased to corporation for business use not part of principal residence 160
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) individual shareholder not entitled to claim CCA on building constructed by the corporation for use in its business even if where taxpayer owns it 160
Tax Topics - General Concepts - Ownership whether tenant had Quebec right of superficies to garage erected by it determined whether it was its property 91
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property building erected by corporation on shareholder’s land not depreciable property unless shareholder renounces right of accession 223

7 October 2011 Roundtable, 2011-0407291C6 F - Group Life Insurance Policy

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Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (d) - Subparagraph (d)(ii) CDA addition for receipt of proceeds of policy on life of shareholder 226

7 October 2011 Roundtable, 2011-0413281C6 F - Avantage à un actionnaire et assurance-vie

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11 February 2011 External T.I. 2010-0360001E5 - Shareholder benefit - single purpose corporation

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6 December 2011 TEI Roundtable Q. 5, 2011-0427001C6 - 2011 TEI Q#5 - Distributions from Foreign Corp.

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Tax Topics - Income Tax Act - Section 90 - Subsection 90(3) 2-step approach 148

24 November 2011 External T.I. 2011-0416791E5 F - Shareholder Benefit

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23 June 2011 External T.I. 2011-0397881E5 - 149(1)(l) Entity - Use of Land by Shareholders

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24 January 2011 Internal T.I. 2010-0389251I7 F - Farm-out agreement and warrants

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Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (j) CEE to be incurred under simple farmout reduced by an allocation to warrants issued by farmee 156
Tax Topics - General Concepts - Fair Market Value - Options amount allocated out of consideration to “free” warrants based on the greater of their trading and in-the-money value 191
Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) application of farmout policy to situation where free warrants issued along with incurring of CEE 214

8 October 2010 Roundtable, 2010-0373251C6 F - Immeuble détenu par une société

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Memorandum TPM-03 "Downward Transfer Pricing Adjustments Under Subsection 247(2)," 20 October 2003

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8 October 2010 Roundtable, 2010-0373311C6 F - Oeuvres d'artistes étrangers

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Tax Topics - Income Tax Act - Section 54 - Listed Personal Property art work in corporate boardroom is not personal use property, perhaps also where decorates office 197
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(e) foreign art work decorating corporate offices is non-depreciable 129

2 June 2008 External T.I. 2008-0264161E5 F - Benefit Conferred to a Shareholder

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30 August 2004 External T.I. 2003-000135 -

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27 March 2008 External T.I. 2006-0200451E5 F - Syndicat de copropriétaires

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Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) distribution of land by Quebec condominium syndicate would cause it to lose its NPO status 65
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation condominium syndicate described in CCQ Art. 1039 is a corporation 35

2003 Ruling 2002-0174703 - Foreign Affiliate Reorganization

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26 March 2003 External T.I. 2001-0105315 - INTERCORPORATE DEBTS

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3 January 2003 External T.I. 2002-0143965 - Shareholder Benefit on First Share Issue

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Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) share subscription at under-value 63

22 February 2002 Internal T.I. 2001-010186 -

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6 February 2002 External T.I. 2001-0105605 - Tax Treatment of Transaction Costs

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2001 Ruling 2001-0105883 - reimbursement of stock option benefit

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20 November 2001 External T.I. 2001-0096865 - Single Purpose Corporations

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9 October 2001 External T.I. 2000-0034915 - REIMBURSEMENT OF STOCK OPTION BENEFIT

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6 November 2000 Internal T.I. 2000-0050427 - PRIVATE AIRCRAFT

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2000 Ruling 2000-0001853 - Waived dividends

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1999 Ruling 9902593 - STOCK OPTIONS - CASH-OUT RIGHT

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Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) use of employee bond to acquire foreign parent share at initial value 241
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) cash surrender of subscription rights for unlisted shares 266

2000 Ruling 2000-0001853 - Waived dividends

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2 December 1999 Internal T.I. 1999-0010070 - Guarantee fee

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1999 Ruling 9830143 - FOREIGN AFFILIATE - LOAN TO CANADIAN PARENT

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14 January 1999 External T.I. 9828555 - CHANGE TO DIVIDEND RATE

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2 May 1997 External T.I. 9708215 - INTERACTION OF 15(1) AND 86(2)

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27 November 1996 External T.I. 9620635 - gift of remainder interest of ecologically sensitive LAND

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Tax Topics - Income Tax Act - Section 43.1 58

27 June 1995 External T.I. 9324765 - SHAREHOLDER BENEFIT ON ISSUANCE OF RIGHTS

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13 February 1995 External T.I. 9503235 - SINGLE PURPOSE CORPORATION-OWNS CANADIAN PROPERTY-7761-1

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94 C.P.T.J. - Q. 26

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26 July 1994 External T.I. 9402515 - APPLICATION OF SUBSECTION 15(1) IN A SPECIFIC SITUATION

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20 June 1994 External T.I. 9405535 - DIVIDEND REINVESTMENT AND STOCK OPTION PLANS

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16 May 1994 External T.I. 9404565 - COURT ORDERED CORPORATE DISTRIBUTION

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27 March 1994 Internal T.I. 9333227 - SHAREHOLDER BENEFIT

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25 March 1994 External T.I. 9335505 - INTEREST REDUCE 15(1) BENEFIT

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8 March 1994 Internal T.I. 9330927 - SHAREHOLDER BENEFIT

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93 C.P.T.J. - Q. 37

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9 July 1993 External T.I. 9306605 - WHETHER CORPORATION CAN MAKE DONATION RATHER THAN ESTATE

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7 April 1993 Memorandum (Tax Window, No. 31, p. 6, ¶2513)

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13 January 1993 T.I. 922191 (November 1993 Access Letter, p. 500, ¶C76-077)

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92 C.R. - Q.51

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92 C.R. - Q.32

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Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) 55

October 1992 Central Region Rulings Directorate Tax Seminar, Q. G (May 1993 Access Letter, p. 230)

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Tax Topics - Income Tax Act - Section 212 - Subsection 212(2) 24

19 June 1992 External T.I. 5-921435 -

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8 April 1992 T.I. (913412 (March 1993 Access Letter, p. 83, ¶C180-135; Tax Window, No. 18, p. 10, ¶1847)

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Tax Topics - Treaties - Income Tax Conventions - Article 10 69

6 April 1992 T.I. (Tax Window, No. 18, p. 3, ¶1851)

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18 March 1992 T.I. (Tax Window, No. 18, p. 4, ¶1816)

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Tax Topics - Income Tax Act - Section 69 - Subsection 69(3) 65

1992 Prairie Provinces Tax Conference, Revenue Canada Round Table, Q. 16 (October 1992 Access Letter, p. 41)

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91 C.R. - Q24

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91 C.R. - Q.16

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91 C.R. - Q.30

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Tax Topics - Income Tax Act - Section 69 - Subsection 69(3) 46

30 November 1991 Round Table (4M0462), Q. 3.2 - Inter-Company Loan (C.T.O. September 1994)

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8 November 1991 T.I. (Tax Window, No. 12, p. 8, ¶1561)

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September 1991 Memorandum (Tax Window, No. 10, p. 22, ¶1482)

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21 August 1991 T.I. (Tax Window, No. 8, p. 16, ¶1399)

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20 September 1991 T.I. (Tax Window, No. 9, p. 18, ¶1465)

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19 July 1991 T.I. (Tax Window, No. 7, p. 8, ¶1363)

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10 July 1991 Memorandum (Tax Window, No. 5, p. 21, ¶1340)

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4 June 1991 T.I. (Tax Window, No, 4, p. 26, ¶1277)

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10 May 1991 T.I. (Tax Window, No. 3, p. 26, ¶1229)

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8 May 1991 T.I. (Tax Window, No. 3, p. 27, ¶1245)

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28 March 1991 T.I. (Tax Window, No. 1, p. 8, ¶1177)

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1 February 1991 T.I. (Tax Window, Prelim. No. 3, p. 27, ¶1115)

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22 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 6, ¶1102)

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15 October 1990 T.I. (Tax Window, Prelim. No. 1, p. 18, ¶1028)

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90 C.R. - Q8

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14 June 1990 T.I. (November 1990 Access Letter, ¶1507)

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28 May 1990 T.I. (October 1990 Access Letter, ¶1453)

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10 May 1990 T.I. (October 1990 Access Letter, ¶1452)

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17 April 1990 T.I. (September 1990 Access Letter, ¶1409)

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27 March 1990 TI (August 1990 Access Letter, ¶1364)

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Tax Topics - General Concepts - Effective Date 36

27 March 1990 T.I. (August 1990 Access Letter, ¶1365)

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23 February 1990 T.I. (July 1990 Access Letter, ¶1340)

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15 January 1990 T.I. (June 1990 Access Letter, ¶1255)

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11 December 1989 T.I. (May 1990 Access Letter, ¶1208)

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4 December 1989 T.I. (May 1990 Access Letter, ¶1208)

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89 C.R. - Q.24

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89 C.R. - Q9

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17 July 89 T.I. (Dec. 89 Access Letter, ¶1043)

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ATR-22R (14 April 89)

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ATR-36 (4 Nov. 88)

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88 C.R. - Q.2

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87 C.R. - Q.33

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ATR-9 (12 May 86)

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86 C.R. - Q.62

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16 July 1985 Memo 7-4095

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85 C.R. - Q.14

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85 C.T. - Q.53

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81 C.R. - Q.49

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Tax Topics - General Concepts - Fair Market Value - Other 45

81 C.R. - Q.51

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80 C.R. - Q.20

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IT-96R5 "Options Granted by Corporations to Acquire Shares, Bonds or Debentures" under "Shareholder Benefit"

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Tax Topics - General Concepts - Fair Market Value - Shares 60

Articles

Perry Truster, "Taxable Benefits: How Much is Taxable?", Tax For The Owner-Manager, Volume 14, Number 2, April 2014, p. 2

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Patrick W. Marley, Kim Brown, "Foreign Mergers and 'Demergers' Under Recent Canadian Proposals", Tax Management International Journal, 10 February 2012, Vol 41, No. 2, p. 86

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Gordon Funt, Joel A. Nitikman, "FAPI and Debt Forgiveness - Now You See It, Now You Don't", CCH Tax Topics, No. 1724, 24 March 2005.

David Louis, Michael Goldberg, "Life Insurance: Exploring the Corporate Edge - Part II", Tax Topics No. 1682, June 3, 2004, p. 1.

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Tax Topics - Income Tax Act - Section 148 - Subsection 148(7) 0

Ramaseder, "Substantial Tax Cost May be Associated with Recreational Properties", Taxation of Executive Compensation and Retirement, November 1991, p. 515.

Crawford, "The Personal Use by a Shareholder of Company-Owned Assets and the Youngman Case", 1990 Conference Report, p. 4:35

Durnford, "Benefits and Advantages Conferred on Shareholders", Canadian Tax Journal, May-June 1984, p. 445.

David A. Ward, "Insurance Funding of Buy-Sell Agreements", 1974 Canadian Tax Journal, p. 484

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Paragraph 15(1)(b)

Cases

The Queen v. Sills, 85 DTC 5096, [1985] 1 CTC 49 (FCA)

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Administrative Policy

2013 Ruling 2012-0463611R3 - Foreign Divisive Reorganization

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23 May 2013 IFA Round Table, Q. 2

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Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) 197

Articles

Durnford, Toope, "Spousal Support in Family Law and Alimony in the Law of Taxation", Canadian Tax Journal, 1994, Vol. 42, No. 1, p. 1.