Income Tax Severed Letters - 2021-06-09


2021 Ruling 2021-0884881R3 F - Supplemental ruling

Principales Questions: Supplemental ruling in respect of our rulings letter for 2020-085260.

Position Adoptée: The rulings in file 2020-085260 will continue to be valid.

Raisons: The changes to do not affect our conclusions.

Technical Interpretation - External

26 October 2020 External T.I. 2020-0856791E5 - CEWS - meaning of inflow

Unedited CRA Tags
CRA will not issue rulings or TIs on what is normal accounting practice for CEWS purposes

Principal Issues: Would the CRA be willing to provide additional examples of how “inflow” should be interpreted for the purposes of determining qualifying revenue and, specifically, whether “inflows” should reflect amounts that get invoiced or amounts that ultimately get booked as revenue (which may not be the same e.g. pass through costs)?

Position: General comments provided

Reasons: See below

Technical Interpretation - Internal

7 June 2021 Internal T.I. 2020-0873601I7 - CERS – restricted activities of a travel agency

Unedited CRA Tags
125.7(1); 125.7(2.1)
a COVID lockdown closing a travel agency office qualified as a “public health restriction” even if the personnel continued bookings from home

Principal Issues: Is a travel agency, which is required to close its office due to certain lockdown measures in effect in the city where it is located, eligible for the rent-top up percentage (lockdown support) in subsection 125.7(2.1) where employees are able to perform their duties from home?

Position: Yes, it is possible assuming all other conditions are satisfied.

Reasons: See response.

7 June 2021 Internal T.I. 2021-0880401I7 - CERS - Lockdown Support Restricted Activities

Unedited CRA Tags
a CODID lockdown closing in-store shopping or seated restaurant dining can be a “public health restriction” notwithstanding curbside pickups or deliveries/take-out

Principal Issues: 1. Whether lockdown support is available for a store located in a shopping mall where a public health order mandates the closure of the store to customers such that sales may only be delivered to customers or picked-up by them at a central location within the mall. 2. Whether lockdown support is available for a restaurant in a shopping mall where a public health order requires the closure of the food court seating area.

Position: 1 and 2. Question of fact, but it is possible.

Reasons: 1 and 2. In these situations, it is possible that an entity has "restricted activities".