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Summary of 27 February 2020 CBA Roundtable, Q.21 under ETA s. 123(1) – permanent establishment. ...

Summary of 27 February 2020 CBA Roundtable, Q.22 under ETA s. 123(1) – university. ...

Summary of 17 May 2021 Internal T.I. 2020-0870041I7 under s. 125.7(1) – qualifying property. ...

CRA indicated that the subleasing of the land would be regarded as the supply of “part of a residential complex” – except that if the land was a site in a residential trailer park, the s. 123(1) definition of residential complex as it applied (in para. ...

Summaries of 15 June 2021 STEP Roundtable, Q.14 under s. 248(1) – GRE, s. 104(24) and s. 104(27). ...

4 July 2021- 10:10pm CRA indicates that it will use “discretion” in its first 12 months of administering the new GST/HST e-commerce rules Email this Content After discussing the legislative proposals, to generally take effect on July 1. 2021, regarding cross-border digital products and cross-border services (which it described as extending to “traditional services such as legal and accounting services … [supplied] to consumers in Canada”), goods supplied through fulfillment warehouses in Canada, and platform-based short-term accommodation, CRA stated: Where the affected businesses and platform operators show that they have taken reasonable measures to comply but are unable to meet their new obligations for operational reasons, the CRA will take a practical approach to compliance and exercise discretion in administering these measures during a 12-month transition period, starting July 1, 2021. ...

CRA also helpfully stated (regarding a Quebec “counter letter” establishing that the true owner is different from that named in the sale agreement): [I]n certain cases, the CRA could issue a letter to the taxpayer confirming that it is not necessary to withhold tax or to obtain a certificate of compliance under section 116, thereby recognizing the legal effect of a counter letter …. ...

Summary of 8 October 2021 APFF Financial Strategies and Instruments Roundtable, Q.4 under s. 123.4(1)- full rate taxable income – (b). ...

CRA indicated that having claimed the s. 20(1)(ww) deduction would not preclude X from subsequently claiming the s. 20(1)(j) deduction when the loan was repaid – and indicated that this appeared to be the right policy result. ...

29 November 2021- 11:23pm CRA indicates that s. 86.1 treatment is not available where a spin-off is structured as a share exchange transaction Email this Content The definition of eligible distribution in s. 86.1(2) accommodates the packaging by a US public company (US Pubco) of a portion of itself into a subsidiary (the Spinco), followed by a dividend-in-kind by US Pubco of the Spinco shares to its shareholders – so that, provided the other conditions are satisfied, the Canadian shareholders can receive rollover treatment. ...