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Or should only realized foreign exchange gain or loss arising in the course of the ordinary activities of the eligible entity—generally from the sale of goods, the rendering of services and the use by others of resources of the eligible entity—be included in the computation of qualifying revenue? CRA Response The term “qualifying revenue” is defined in subsection 125.7(1) of the Income Tax Act (“the Act”), in part, as follows: “qualifying revenue, of an eligible entity for a prior reference period or a current reference period, means the inflow of cash, receivables or other consideration arising in the course of the ordinary activities of the eligible entity — generally from the sale of goods, the rendering of services and the use by others of resources of the eligible entity — in Canada in the particular period, …” Subsection 125.7(4) of the Act provides that, for the purposes of the definition “qualifying revenue” in subsection 125.7(1) of the Act, the qualifying revenue of an eligible entity is to be determined in accordance with its normal accounting practices, subject to certain choices and elections available to the eligible entity. ... However, in order to be considered qualifying revenue, an inflow of cash, receivables or other consideration must also arise in the course of an entity’s ordinary activities in Canada, generally from the sale of goods, the rendering of services and the use by others of resources of the entity. ...

The CRA’s newly issued communiqué AD-19-02 – Obtaining Information for Audit Purposes, provides guidance to auditors on the CRA’s policy for the purpose of administering the ITA. ... FID is dependent on many things including a particular taxpayer’s circumstances, critical time path, availability of equipment, and resources. ... Could the CRA please confirm that the foregoing interpretation would be unreasonable in light of the context and purpose of the Accelerated CDE rules, and that the Exclusion generally should apply only in the context of Canadian resource property acquired by a taxpayer from a non-arm’s length party? ...

Position: Presently, as stated in Technical News No. 3 & 9. Awaiting decision from Federal Court of Appeal to determine if we will change our position to be consistent with the decision in Mark Resources. Reasons: SPEAKING NOTES FOR RICK BISCARO FOR GOODMAN PHILLIPS & VINEBERG & CHARTERED ACCOUNTANTS OF ONTARIO ROUND TABLE, MAY 27, 1998 Treatment of Losses for Tax Purposes Query Limits on in-house loss utilization? ... The Tax Court of Canada decisions in Mark Resources (93 DTC 1004) and Canwest Broadcasting (96 DTC 1375) indicate it is arguable that borrowed money in schemes involving the borrowing of money by one corporation in the group (e.g. see income tax ruling ATR-44 or example 5 of Information Circular 88-2 Supplement 1), do not meet the requirements in paragraph 20(1)(c) that the borrowed money be used for the purpose of earning income, when the overriding economic purpose is to save taxes within the group. ...

Hiltz) indicated that, subsequent to a final decision in the appeal of Mark Resources, Inc. v. ... SCIENTIFIC RESEARCH & EXPERIMENTAL DEVELOPMENT — T661 The simple answer is yes. ... The Audit Protocol- Improving the audit process is also available from any Revenue Canada tax services office. — 17 — ...

Question #4 RESOURCE ALLOWANCE Is Revenue Canada working on an Information Circular concerning the calculation of resource allowance prior to July 1992 in order that a number of taxpayers not privy to the CAPP agreement are aware of the resolution of the issues? ... Question # 11 WAGE LOSS REPLACEMENT PLANS- IT-428 a) In Interpretation Bulletin IT-428, the rules for "Wage Loss Replacement Plans" are outlined. ... Question # 20 DEDUCTIBILITY OF SALES TAX REASSESSMENT What is the impact of the Johnson & Johnson Inc. case 94 DTC 6125 on the Department's policy with regard to the timing of the deductibility of sales tax reassessments for income tax purposes as enunciated in Information Circular 77-11? ...

We are currently working on the income tax folio that will update and replace IT-87R2, as resources permit. ... The process of writing and updating Folios is very resource-intensive. ... As resources permit, ITRD continues to work on the Folio that will replace IT-87R2. ...

Reasons: Question of fact and law to be determined on a case by case basis. 2022 CTF Annual Conference CRA Roundtable Question 14: Charities – Transfer of Property to a Grantee Organization Background Recently, the Income Tax Act (Act) was amended to permit Canadian registered charities to make disbursements by way of a gift or by otherwise making resources available to a “grantee organization” which is defined to include a person, club, society, association or organization or prescribed entity, but not a qualified donee. ... CRA Response Prior to recent amendments, the Income Tax Act (Act) required that a registered charity devote its resources to charitable activities that the charity carried on itself or to providing gifts to qualified donees. ... Bill C-19 (endnote 1) amended the Act to allow a registered charity to make a qualifying disbursement, by way of a gift or otherwise making resources available, to a grantee organization, provided that the disbursement is in furtherance of a charitable purpose of the charity and the charity ensures that the disbursement is exclusively used to advance charitable activities in furtherance of a charitable purpose of the charity. ...

19 May 2021 CLHIA Roundtable Q. 3, 2021-0884281C6- 2021 CLHIA Roundtable- Q3- Folios Unedited CRA Tags 148 Principal Issues: This question and answer deals with the current status of the Income Tax Folio Project and in particular, the Income Tax Folio that will replace IT-87R2, Policyholder's Income from Life Insurance Policies Position: Update provided Reasons: NA 2021 CLHIA Roundtable Question 3 – Tax Folio on Life Insurance Dispositions Background: At the CALU 2014 CRA Roundtable (Question 2) CALU noted that the Income Tax Rulings Directorate (ITRD) had started to update and improve the technical content contained in Interpretation Bulletins through the creation of a new technical tax publication called Income Tax Folios. ... The process of writing and updating Folios is very resource-intensive. ... As resources permit, ITRD continues to work on the Folio that will replace IT-87R2. ...

STEP CRA Roundtable – June 13, 2017 QUESTION 14 – Dedicated Telephone Service The Income Tax Rulings Directorate recently confirmed at the 2017 CPA-BC & CRA Roundtable the CRA’s plan to introduce a new dedicated telephone service (DTS) for income tax service providers, which was originally announced in Budget 2016. ... Under the DTS pilot project, registration is open to small accounting practitioners in Ontario and Quebec – namely, CPAs who are in public practice as sole proprietors or in groups of up to three professional partners or shareholders. ... While the DTS is intended to be a technical resource for those who are in the business of preparing income tax returns, the service is not intended to be a problem resolution line for dealing with specific taxpayer issues. ...

Will the CRA be able to add resources or devote additional resources from other sources in order to ensure that taxpayers have access to income tax technical publications and that the Folios remain current? ... Answer 1(c)(ii) We hope to launch the Income Tax Folios with an initial publication of 10 – 12 Folio Chapters and have targeted early 2013 for these releases. ... Similar to the IT Bulletins, they were numbered chronologically, from ATR 01 – ATR 70. ...