Income Tax Severed Letters - 2020-10-07

Technical Interpretation - External

21 September 2020 External T.I. 2020-0855831E5 - CEWS - qualifying revenue

Unedited CRA Tags
125.7(1)
the percentage of completion method can be used in computing qualifying revenue, but not marking securities to market
recognition of qualifying revenue based on an inflow requirement
Words and Phrases
revenue

Principal Issues: (1) Is revenue of an eligible entity determined under the percentage of completion method considered qualifying revenue under subsection 125.7(1)? (2) Are unrealized gains/losses of investments arising from mark-to-market adjustments to the carrying amount of the investments under accounting practices included in qualifying revenue?

Position: (1) Likely yes. (2) Unrealized gains/losses arising from mark-to-market valuation adjustment to investments are not included in qualifying revenue.

Reasons: (1) The services performed under a contract generally give rise to an inflow of cash, receivables or other consideration in the qualifying period. (2) Unrealized gains/losses arising from mark-to-market valuation adjustment to investments do not give rise to an inflow of cash, receivables or other consideration.

12 August 2020 External T.I. 2019-0833841E5 - MIC Shareholder Count - Joint holders

Unedited CRA Tags
130.1(6)(d), 130.1(7)
joint tenants holding a share may be one shareholder, not two
Words and Phrases
joint tenancy
joint tenants potentially treated as single security holder

Principal Issues: How should joint shareholders be counted for purposes of 130.1(6)(d)?

Position: General comments provided.

Reasons: Legal determination.