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22 December 2020 GST/HST Interpretation 209955 - – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […] -- summary under Subsection 259(2)

22 December 2020 GST/HST Interpretation 209955- – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […]-- summary under Subsection 259(2) Summary Under Tax Topics- Excise Tax Act- Section 259- Subsection 259(2) CEWS and TWS did not count towards 40% government funding A non-profit organization (NPO) generally is entitled to GST/HST public service body rebates if the percentage of its “government funding” (defined in s. 2 the Public Service Body Rebate (GST/HST) Regulations) is at least 40%. ... CRA concluded that the CEWS was not government funding under the definition, given that it “is a refund in respect of income taxes imposed under the ITA” and it “is not paid for the purpose of financially assisting the NPO in carrying out the purposes of the NPO. “ CRA applied a somewhat similar analysis to find that the 10% temporary wage subsidy for employers program also did not count as government funding. ...

22 December 2020 GST/HST Interpretation 209955 - – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […] -- summary under Government Funding

22 December 2020 GST/HST Interpretation 209955- – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […]-- summary under Government Funding Summary Under Tax Topics- Excise Tax Act- Regulations- Public Service Body Rebate (GST/HST) Regulations- Section 2- Government Funding CEWS received by an NPO does not qualify as government funding for GST/HST PSB rebate purposes Are the Canada emergency wage subsidy (“CEWS”) and the 10% temporary wage subsidy for employers (“TWS”) programs considered government funding for purposes of s. 2 the Public Service Body Rebate (GST/HST) Regulations? After noting that s. 2 excluded a “refund, rebate or remission of, or credit in respect of, taxes” and referenced a purpose of “financially assisting the particular person in carrying out the purposes of the particular person” and further indicating that the purpose of the two programs was to “re-hire workers previously laid off as a result of COVID-19, help prevent further job losses, and better position businesses to resume normal operations following the crisis,” CRA found that the CEWS was not government funding under s. 2, given that it “is a refund in respect of income taxes imposed under the ITA” and it “is not paid for the purpose of financially assisting the NPO in carrying out the purposes of the NPO. “ Regarding the TWS, it also noted that an eligible employer does not reduce its deductions from its employees’ pay and remits less to the Receiver General. ...

In re Income Tax Act (Manitoba) / Thos. Jackson & Sons, Ltd. v. The Municipal Commissioner, [1936] SCR 616

In re Income Tax Act (Manitoba) / Thos. Jackson & Sons, Ltd. v. The Municipal Commissioner, [1936] S.C.R. 616 Supreme Court of Canada In re Income Tax Act (Manitoba) / Thos. ... S. 4 (p) (enacted in 1930. c. 22) provided that “profits of a * * * joint stock company * * * accumulated prior to and undistributed at” December 31, 1929, be not liable to taxation under s. 8 (4). ... Solicitors for the appellant: Johnston, Major, Finlayson & Fraser. ...

29 November 1991 Internal T.I. 912299 F - Ontario R & D Superallowance and the Quebec R & D Tax Credit

29 November 1991 Internal T.I. 912299 F- Ontario R & D Superallowance and the Quebec R & D Tax Credit Unedited CRA Tags 12(1)(x), 13(7.1), 37(1)(d) Dear Sirs: Re: Ontario R & D Superallowance and the Quebec R & D Tax Credit This is in reply to your letter of August 13, 1991 concerning certain government allowances and credits provided by Ontario and Quebec. ... It is your understanding that any Ontario income tax savings resulting from "grossed up amounts" or "phantom deductions" provided by the Ontario Superallowance and OCCA are treated as follows for federal income tax purposes:- will not be regarded as an inducement that must be included in income pursuant to paragraph 12(1)(x) of the Act;- will not require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act;- will not be regarded as government assistance and therefore will not reduce the amount that may be deducted under paragraph 37(1)(d) in respect of expenditures on scientific research and experimental development; and We confirm this understanding. Furthermore, it is your understanding that any payment of tax that is deemed to be made to Quebec as a result of the Quebec Research and Development Tax Credit provisions will receive one or more of the following treatments for federal income tax purposes:- will be regarded as an inducement that must be included in computing the taxpayer's income pursuant to paragraph 12(1)(x) of the Act;- will require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act;- will be regarded as government assistance and therefore will reduce the amount that may be deducted under paragraph 37(1)(d) of the Act in respect of expenditures on scientific research and experimental development; and- will reduce the amount of the capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ...

8 November 1989 Ministerial Letter 73828 F - Integrated Sawmill & Pulpmill - M & P Deduction

8 November 1989 Ministerial Letter 73828 F- Integrated Sawmill & Pulpmill- M & P Deduction Unedited CRA Tags 5202, 125.1(1) November 8, 1989 Carole Gouin-Toussaint Rulings Directorate Director Frank Gillman Bilingual Services & Resource Industries Division 7-3828 The Special Audits Division has requested that we withdraw one of our previous opinions which states that the "transportation activity of woodchips between the sawmill and the pulpmill which occurs within an integrated operation, be included as a qualified activity within the meaning of section 5202 of the Regulations so that the capital and labour costs of transporting the chips be included in the calculation of the M & P deduction. ... (ii) receiving and storing of raw materials, (iii) handling of goods in process... (b) all other activities... directly in connection with manufacturing or processing... but does not include any of (d) ... shipping... of finished goods, (e) purchasing of raw materials... ...

Montreal Coke and Manufacturing Co. v. Minister of National Revenue / Montreal Light, Heat & Power Consolidated v. The Minister of National Revenue, [1942] SCR 89

Minister of National Revenue / Montreal Light, Heat & Power Consolidated v. ... The particulars of the disbursements made by the Company in connection with this operation were as follows: (i) Interest on new bonds from September 16, 1935, to December 31, 1935, until when interest had to be paid on both the old and new bonds $ 23,207 54 (ii) Various expenses on retiring the old bonds and issuing the new bonds 12,484 92 (iii) Discount on issue of new bonds 28,000 00 (iv) Premium paid upon retirement of issue of old bonds 69,140 00 (v) Exchange premium paid on retirement of old bonds 36,744 81 $169,577 27 The first two items of expenses mentioned above were charged directly against the earnings for 1935. ...

10 June 2019 Internal T.I. 2019-0796221I7 F - Qualification d’un véhicule à titre de « voiture de tourisme »

Position Adoptée: Non / No Raisons: Application de la Loi. / Application of the Act. ... Commentaires généraux Voiture de tourisme La définition de l’expression « voiture de tourisme » est tributaire de la définition du terme « automobile », tous deux définis au paragraphe 248(1). ... La définition d’« automobile » au paragraphe 248(1) ne précise pas le moment où la condition exigeant qu’un bien soit « acquis principalement pour servir de taxi » doit être satisfaite. ...

22 December 2020 GST/HST Interpretation 209955 - – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […]

22 December 2020 GST/HST Interpretation 209955- – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […] Unedited CRA Tags Public Service Body Rebate (GST/HST) Regulations- Section 2 Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. Excise and GST/HST Rulings Directorate Legislative Policy and Regulatory Affairs Branch 10-320 Queen Street, Tower A Ottawa, ON K1R 5A3 [Addressee] Case Number: 209955 [Dear Client] Subject: [GST/HST Interpretation] [Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […] We are writing in response to your [correspondence] of May 25, 2020, wherein you request that we rule on whether the […][Canada Emergency Wage Subsidy (“CEWS”)] and […][10% Temporary Wage Subsidy for Employers (“TWS”)] programs are considered government funding for purposes of the Public Service Bodies’ (“PSB”) Rebate. ... For additional information on the CEWS program, see the Canada.ca webpage frequently asked questions – Canada emergency wage subsidy (CEWS). 3. ...

Robotx Solutions Inc. v. The Queen, 2017 TCC 73 (Informal Procedure) -- summary under Scientific Research & Experimental Development

The Queen, 2017 TCC 73 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development solving narrowly-cast production engineering problems was not SR&ED The taxpayer was a corporation that improved customer’s equipment by increasing their lifespan, improving their security mechanisms or by standardizing them in order to produce economies of scale. In 2012, it entered into four separate contracts with four customers to provide them with specific solutions within the scope of this services business, and treated $182,483 of the expenditures which in incurred in the course of performing this customer-specific work as SR & ED expenditures. Respecting the first project undertaken for an alcohol products company, Jorré J stated (at paras 50, 58, and 62-63, TaxInterpretations translation): … [T]he purpose of the project was to make the palletizers and depalletizers [of beverage bottles] conform to current security standards and to eliminate the risk of the lifting platform falling when an operator or mechanic was underneath. … … [T]here is nothing in the evidence that suggests that palletizers and depalletizers meeting the required safety standards do not already exist or that there is an improvement over what already existed. … … Difficulties by themselves are not sufficient for their resolution to become experimental development. ...

23 June 2014 External T.I. 2014-0528271E5 F - Terrain « adjacent » à la résidence principale

Faits En XXXXXXXXXX, vous et votre conjointe avez acheté un terrain en copropriété sur le bord d'une rivière (« Terrain 1 »). ... D'après les faits, tous les critères sont remplis, sous réserve de la signification de « fonds de terre adjacent ». ... La version anglaise de la Loi traduit l'expression « terrain adjacent » par « immediately contiguous land ». ...

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