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.) … 4. The loan should be made primarily for the purpose of avoiding a deemed gain under s. 40(3.1) that would be realized by the partner at the end of the partnership’s fiscal period, and that would solely be due to the timing difference between the addition in, and deduction from, the calculation of the ACB of the partnership interest related to the partner’s share of the partnership-adjusted income, and the distributions to the limited partner in respect of the period on their side. ...

1 December 2022- 11:25pm CRA treats the cancellation of escrow shares as triggering a deemed dividend Email this Content Under an agreement for the sale of the target solely for shares of the purchaser, a portion of such shares were placed in escrow at the time of their valid issuance – then were subsequently cancelled to satisfy an obligation of the vendor to repay a downward adjustment to the purchase price equal to such shares’ value (which exceeded their paid-up capital). ...

. … The set-off was not permitted. Neal Armstrong. Summaries of Agence du revenu du Québec v. ...

.” – which is a question of fact. A gift card that entitles a person to redeem the card for a particular product or service, or that is redeemable for a time-limited (e.g., 6 months) subscription service will still qualify as a gift certificate where all the attributes listed in P-202 are met. ...

Summaries of 16 January 2023 Internal T.I. 2020-0851561I7 F under s. 125.7(1) – eligible remuneration, and baseline remuneration. ...

In granting leave, the Supreme Court indicated that this appeal will be heard with Dow Chemical ULC – presumably, on the basis that both deal with the demarcation of the respective jurisdictions of the Federal Court and Tax Court. ...

Thus, the issue would turn on whether there was substantial renovation of the physical space for each proposed condo unit – with CRA reiterating in this regard its longstanding position that to rise to the level of substantial renovation there would need to be a gutting (or more) of each unit at issue. ...

In finding that s. 190(1) would not apply, CRA noted that the s. 190(1) preamble requires that a person begins to hold or use real property as a residential complex – whereas here, the person (NewCo) held a single residential complex both before and after the transaction (merely expanding the size of its residential complex). ...

Summary of GST/HST Memorandum 18-4 “Determining Whether a Transfer Payment is Consideration For a Supply” June 2022 under ETA s. 123(1) – consideration. ...

It stated: [T]he Notice of Intent … is a compliance tool to be used at the disposal of the CRA; it is not taxpayer-initiated. ...