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Summary of May 2019 CPA Alberta CRA Roundtable, GST Session – Q.10 under ETA s. 256.2(7). ...

Summary of May 2019 CPA Alberta CRA Roundtable, GST Session – Q.20 under ETA s. 156(4). ...

As such … it is not possible for a foundation to make a gift to a qualified donee in the course of carrying on of its own charitable activities. ...

However … [i]n this particular [COVID] context, the Canada Revenue Agency is prepared to accept that the reimbursement, upon presentation of supporting documentation, of an amount not exceeding $500, of all or part of the cost of acquiring personal computer equipment to enable the employee to immediately and properly perform the employee’s work, is primarily for the benefit of the employer, so that it does not result in a taxable benefit to the employee. ...

However, since the joint election must be made with all group members, the qualifying revenue of each one should be examined – for example, the passive income of the individual’s spouse. ...

6 August 2020- 11:36pm Supreme Court grants leave in Alta Energy Email this Content Alta Energy rejected what essentially was a Crown position that Treaty-shopping (here, transferring an investment in a Canadian resource company to a Lux holding company followed by a sale, two years later, that was Treaty-exempt) was a GAAR abuse – with Webb JA saying, for instance that there “is no distinction in the Luxembourg Convention between residents with strong economic or commercial ties and those with weak or no commercial or economic ties,” and that “the object, spirit and purpose of the relevant provisions of the Luxembourg Convention is reflected in the words as chosen by Canada and Luxembourg.” ...

26 August 2020- 11:20pm CRA’s COVID guidelines do not include dispensation from source deductions for non-resident employers whose employees work from Canada due to travel restrictions Email this Content CRA indicated that where an employee not ordinarily resident in Canada is present in Canada due to COVID-related travel restrictions and works remotely (for the non-resident employer) from Canada, the nonresident employer would now be subject to Canadian withholding obligations (including where the employer did not consent to this work occurring in Canada) unless a waiver of withholding was obtained – including in the situation where it did not consent to this Canadian nexus? ...

2 September 2020- 12:01am CRA indicates that accrual-basis taxpayers should not usually net bad or doubtful debt allowances against their qualifying revenues Email this Content Recently-enacted s. 125.7(4)(e)(ii) allows an eligible entity to elect “to determine its qualifying revenues based on … the accrual method, in accordance with generally accepted accounting principles. ...

This first note then is extinguished by operation of law when the portfolio company is wound-up into Newco a year later – with payments of the second note by Newco to the estate commencing thereafter. ...

CRA indicated that this position was contrary to Shell Canada, which found that absent a specific provision to the contrary or sham, the taxpayer’s legal relationships must be respected – so that withholding tax would not apply in such a situation absent a finding of sham or the application of a specific provision, e.g., s. 245 or 247. ...