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8 May 2017- 11:39pm CRA rules that the Alberta carbon tax is subject to GST Email this Content CRA has ruled that a natural gas distributor is required to include the Alberta carbon-tax levy (which it is required to collect from its customers) in the value of the consideration for such natural gas supplies for GST purposes – so that effectively the Canadian government is imposing GST on the Alberta carbon tax. ...

Summary of Lumenpulse Circular under Mergers & Acquisitions- Mergers- Privatizations. ...

Summary of 5 May 2017 OBA Seminar, Q.7 under Reg. 8500(1) – predecessor employer. ...

27 June 2017- 2:08am CRA automatically pays available dividend refunds even when not claimed (or wanted) Email this Content Although a private corporation with an available claim for a dividend refund (“DR”) is not required to make the claim, CRA considers that it has the discretion to make the DR even when not claimed – and in fact: Currently, the CRA policy… is to automatically make a DR where the information required for the calculation of the DR has been filed on the T2 return (including the Schedule 3/T2SCH3), even where a private corporation does not request it (for example, by entering zero on line 784 of its T2 return). ...

They could not deduct under s. 8(1)(h) the board and lodging fees charged to them because the remote logging camp constituted a place of business of their employer – so that they were not travelling away from their employer's place of business. ...

Summary of 21 June 2017 External T.I. 2016-0678361E5 Tr under s. 89(1) – capital dividend account- s. ...

9 October 2017- 12:11am CRA appears to accept a negative covenant in a TFSA declaration that supports a loan made to the TFSA holder Email this Content A TFSA holder can pledge his or her TFSA interest as security for a loan on arm’s length terms – but, per 2013-0514261E5, the loan may not also be secured by the TFSA assets. ...

Summary of 6 October 2017 APFF Financial Strategies and Instruments Roundtable, Q.6 under s. 146.3(1) – designated benefit. ...

The Queen, 2017 TCC 212 under ETA s. 123(1) – substantial renovation. ...

Summary of Joint Committee, “Subsection 55(2) Amendments – Follow-Up to Our Meeting with Canada Revenue Agency,” 19 January 2018 Joint Committee Submission to Finance respecting s. 2015 s. 55(2) Amendments including appended 20 April 2017 letter to Randy Hewlett on such amendments under s. 55(2). ...