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CRA also noted that, administratively, it: [a]llows … mitigating the effects of an excessive eligible dividend designation by accepting that the election provided for in subsection 185.1(2) can be made by a corporation at the time of filing its income tax return, without having to wait for a notice of assessment of Part III.1 tax to be issued. ...

Summary of 22 February 2021 External T.I. 2018-0784661E5 under s. 122.1(1) – gross REIT revenue. ...

CRA stated that it was “not prepared to take an administrative position to consider that subsection 247(7) would apply in respect of the loan between the FA and LP ….” ...

Summaries of 12 March 2021 External T.I. 2020-0867001E5 under s. 146.3(1) – designated benefit and s. 146.3(3.1). ...

Summary of 11 May 2021 Internal T.I. 2020-0869981I7 under s. 125.7(1) – qualifying rent expense. ...

Summary of 7 June 2021 Internal T.I. 2020-0873601I7 under s. 125.7(1)- public health restriction – para. ...

CRA concluded that the CEWS was not government funding under the definition, given that it “is a refund in respect of income taxes imposed under the ITA” and it “is not paid for the purpose of financially assisting the NPO in carrying out the purposes of the NPO. “ CRA applied a somewhat similar analysis to find that the 10% temporary wage subsidy for employers program also did not count as government funding. ...

13 July 2021- 11:02pm CRA indicates that a s. 149(1)(n) corp. must construct rather than purchase its low-rental housing projects Email this Content S. 149(1)(n) exempts the income of a limited-dividend housing company (within the meaning of … section 2 of the National Housing Act), all or substantially all of the business of which is the construction, holding or management of low-rental housing projects. ...

CRA confirmed that, regarding the narrow issue of the FMV of the common shares immediately before the death of the taxpayer, given that the insurance share was retractable by the holder immediately before the death for the CSV, it would not be unreasonable to allocate the policy CSV to the insurance shares – so that the value of the common shares would not take the policy CSV into account. ...

Summary of 16 July 2021 Internal T.I. 2020-0872521I7 under s. 125.7(1)- “qualifying rent expense” – para. ...