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CRA confirmed that there are no continuity rules for common reorganization transactions, such as amalgamations, s. 88(1) wind-ups or s. 85(1) rollovers, so that such an event or transfer starts the 365-day period running again – so that, for example, it would not help that a housing unit had been held for many years by a predecessor of Amalco, if Amalco promptly disposes of the unit. ...

., again, it would be a question of fact as to whether the lease termination fee constituted an “actual lease charge” and, if it did, it would be added to the more usual lease charges – and if the taxpayer's total annual lease charges exceeded the limit allowed under s. 67.3 including this addition, he would not be able to deduct the excess amount in computing his income under s. 9. ...

CRA indicated that the first alternative did not satisfy the requirement, for the equipment to qualify as Class 53 property, that it be used in the manufacturing or processing of goods for sale – as the goods (the dental restorative products) instead were used in providing a dental service. ...

Summary of 10 October 2024 APFF Financial Strategies & Instruments Roundtable, Q.2 under s. 261(2)(b). ...

Summary of 10 October 2024 APFF Financial Strategies & Instruments Roundtable, Q.7 under s.146.6(15)(a). ...

Under CRA’s arrangement made in 1991 with the Canadian Dental Association, a dentist registrant could, for each reporting period in a fiscal year, use an estimate up to a maximum of 35% of the total consideration charged for orthodontic treatments to represent the consideration for the supply of orthodontic appliances, and claim ITCs on that basis – but then, at the end of the fiscal year, was required to perform a reconciliation based on the actual amounts charged for orthodontic appliances, and adjust the ITC claims for the year accordingly (keeping in mind that charges for cosmetic services also generated ITCs). ...

Summary of 15 July 2024 External T.I. 2023-0990221E5 under s. 54 – principal residence. ...

Summary of 2021 Ruling 2021-0887611R3 under s. 248(1) – SDA. ...

CRA also was somewhat mystified by the question, and indicated that it did not read these provisions as creating circularity – but indicated that, in any event, if such a possibility did exist, it would take a purposive approach to avoid an absurd result. ...

However, on the death of Daughter2, ½ of the Fund property had been distributed in accordance with the Fund terms to her issue. ...