carry on

19 October 2023 Internal T.I. 2020-0856851I7 - Ordinary Course of Business -- summary under Paragraph 258(4)(a)

In 2010, a Canadian corporation, which was a specified financial institution by virtue of being controlled by its parent, a Canadian insurance corporation, subscribed for 9,350,000 mandatory redeemable preferred shares of Luxco 1 (“MRPS” – subsequently, “Class A MRPS”) for US$935,000,000. Luxco 1 used those proceeds to make loans to US foreign affiliates for use in the corporate group’s US operations. In 2012, the MRPS and common shares of Luxco 1 were transferred on an s. 85(1) rollover basis to a Canadian subsidiary (XXXXXXXXXX).

7 October 2022 APFF Financial Strategies and Instruments Roundtable Q. 5, 2022-0936301C6 F - Guarantee fee -- summary under Business

An individual, a sole shareholder of a corporation, borrows money in order to earn business or property income. To secure his personal loan, his corporation grants a mortgage on a building it owns.

5 October 2018 APFF Roundtable Q. 17, 2018-0768881C6 F - entreprise exploitée activement – revenu de location -- summary under Active Business Carried On by a Corporation

Realtyco is a CCPC holding in Canada six buildings each containing 50 residential units, which it rents out. The sole services provided by it to the tenants are maintenance of the common areas and snow removal. There is a full-time caretaker at each building (for six in total).

By services, 28 November, 2015

Thiel v. Federal Commissioner of Taxation, 90 A.TC 4717 (HC of A.) -- summary under Article 3

In January and May 1984 the taxpayer, who was a resident of Switzerland, paid $150,000 to acquire six units in the Energy Research Group Unit Trust, in November 1984 he sold his six units to Energy Research Group Australia Ltd. for $300,000 to be satisfied by the issuance to him of 600,000 ordinary shares of that company, and in 1985, following a listing of the shares on the Australian Stock Exchange, he sold 252,000 of his shares for $566,307.

carry on

carry on

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