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Q.2 … The 14 day remuneration condition should be examined based on whether remuneration was paid in respect of a qualifying period and not on the remuneration that was actually paid during a qualifying period. We have provided some additional guidance in question 17-6 …. Q.3 … Although the value of a non-cash taxable benefit is received by the employee because of employment, the value of such benefit is not eligible remuneration paid to an eligible employee for purposes of computing the wage subsidy. Therefore … remuneration for the purpose of the definition of an “eligible employee” … would not necessarily be the same as “eligible remuneration” paid to an eligible employee for purposes of the calculation of the CEWS …. ...

25 January 2018 External T.I. 2017-0709241E5- Subsections 125(3.2) & 125(5.1)-- summary under Subsection 125(5.1) Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(5.1) business limit is ground first based on taxable capital before it can be assigned Does the assignment of the business limit under s. 125(3.2) occur before or after the business limit reduction in s. 125(5.1)? After noting that under s. 125(5.1) “the business limit … is reduced on a straight-line basis if the total of the taxable capital of the CCPC (employed in Canada) and, if applicable, of [associated] corporations … exceeds $10 million … [so that] once the taxable capital … reaches $15 million its business limit would be zero,” CRA stated:. ...

6 September 2023 Internal T.I. 2019-0805481I7- Interaction of 17.1(1) & 247(2)-- summary under Subsection 247(2.1) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2.1) there is no conflict in applying both ss. 17.1 and 247(2) to impute interest on a PLOI A non-resident corporation (Parent2) which, through a wholly-owned non-resident subsidiary, was the sole shareholder of a corporation resident in Canada (“CRIC”), received various unsecured loans from the CRIC, which bore interest at a floating rate equal to the prescribed rate under Reg. 4301(b.1), payable not less than annually. ... In short … subsection 247(2), which was broadly worded to embody the arm’s length principle, was meant to apply to all cross-border transactions, arrangements or events, including financial transactions, between non-arm’s length persons or partnerships, unless a specific exclusion applies. [See] … 2017-0691071C6 …. ...

29 September 2020 External T.I. 2018-0757501E5 F- Crédit pour intérêts sur les prêts étudiants-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt capitalization of interest on a novation under Quebec law would constitute its payment A Quebec post-secondary student loan program provided for an initial 12-month “full exemption period” (in which the Quebec government paid the interest charged on the loan by the lender) and a subsequent six-month “partial exemption period” (during which the student borrower was required to pay interest on the loan balance). ... In addressing whether such capitalized interest qualified as being “paid” under a “loan made” under the Quebec financial assistance program so as to generate a credit under s. 118.62, CRA stated: By virtue of the Civil Code of Quebec, there can be payment where there is a handing over of money [(“tradition d’argent”)] between the debtor and the creditor or where there is novation by change of debt. … The mere addition of accrued interest to the principal amount of an original debt is generally not sufficient in itself to constitute a payment of such interest. If … the addition of interest to the principal … qualifies as a novation … the amount of interest will be considered paid when the novation occurs and will be eligible for the credit by virtue of section 118.62, if all the conditions set out in that section are otherwise satisfied. ...