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CRA indicated that such receipt of cash sale proceeds would not preclude the s. 73(1) rollover from applying – and that the answer would not change if the settlor subsequently gifted the cash proceeds to an adult child. ...

18 July 2022- 11:38pm CRA indicates that the classification of civil law foundation is determined on a case-by-case basis Email this Content CRA indicated that it will apply its usual two-step approach to foreign entity classification in determining whether a foundation created under the laws of a country where civil law applies is treated as a trust under the Act – and since this is done on a case-by-case, it is not making any blanket pronouncement that such foundations are trusts for such purposes. ...

5 December 2022- 11:17pm CRA indicates that the critical METC certification form will be provided shortly Email this Content Regarding the requirement under the (still) draft rules for an enhanced mineral exploration credit for individuals’ investing in flow-through shares that the required certification by a “qualified engineer or geoscientist” be “completed … no more than 12 months before the time that the agreement is made,” CRA indicated that the prescribed form is in the process of being completed and will be released to the public “very shortly.” ...

14 March 2023- 11:02pm CRA indicates that an Appeals Officer can (and may) increase the reassessment under appeal Email this Content CRA stated that it has the authority under ETA s. 301(3) (equivalent, although not identical, to ITA s. 165(3)) to further increase a reassessment that has been objected to (for example, if a second valuation prepared for the Appeals Officer produced an even higher valuation) – but indicated that “[a]ny upward adjustment must be approved by the Appeals Officer’s manager or the Chief of Appeals.” ...

Summary of GST/HST Info Sheet GI-200, Application of the GST/HST to Credit Card Surcharges, March 2023 under ETA s. 123(1) – financial service- para. ...

Summary of 24 March 2022 GST/HST Ruling 222713 under s. 123(1) – residential unit. ...

Summary of 21 September 2023 External T.I. 2023-0984251E5 under s. 18(1)(a) – income-producing purpose. ...

Summary of 2 November 2023 APFF Roundtable, Q.12 under General Concepts – Evidence. ...

Summary of 23 January 2024 External T.I. 2023-1000021E5 under s. 118.1(1)- "total charitable gifts" – (c)(i)(A). ...

Summary of 26 July 2024 External T.I. 2024-1014761E5 under s. 248(1) – former business property. ...