Income Tax Severed Letters - 2020-10-07

Technical Interpretation - External

Unedited CRA Tags: 
125.7(1)

21 September 2020 External T.I. 2020-0855831E5 - CEWS - qualifying revenue -- attach -- Subsection 125.7(4)

the percentage of completion method can be used in computing qualifying revenue, but not marking securities to market

(a) When is “qualifying revenue” recognized where the eligible entity recognizes revenue under the “percentage of completion” method,...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Revenue recognition of qualifying revenue based on an inflow requirement 141

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

recognition of qualifying revenue based on an inflow requirement

S. 125.7(4) requires that qualifying revenue of an eligible entity generally “be determined in accordance with its normal accounting...

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Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(4) the percentage of completion method can be used in computing qualifying revenue, but not marking securities to market 282

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.

Unedited CRA Tags: 
130.1(6)(d), 130.1(7)

12 August 2020 External T.I. 2019-0833841E5 - MIC Shareholder Count - Joint holders -- attach -- Paragraph 130.1(6)(d)

joint tenants holding a share may be one shareholder, not two

How would the 20-shareholder and 25% tests in s. 130.1(6)(d) be applied where a husband and wife hold a share as joint tenants (with rights of...

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Tax Topics - Income Tax Regulations - Regulation 4801 - Paragraph 4801(b) joint tenants potentially treated as single security holder 119

12 August 2020 External T.I. 2019-0833841E5 - MIC Shareholder Count - Joint holders -- attach -- Paragraph 4801(b)

joint tenants potentially treated as single security holder

S. 130.1(6)(d) requires inter alia that a mortgage investment corporation have at least 20 shareholders. How is this test applied where a husband...

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Tax Topics - Income Tax Act - Section 130.1 - Subsection 130.1(6) - Paragraph 130.1(6)(d) joint tenants holding a share may be one shareholder, not two 199

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

Position: General comments provided.

Reasons: Legal determination.