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CRA reiterated its position in IT-434R that “the renting of real property by an individual … will be regarded as a business operation only when the landlord supplies or makes available to tenants services of one kind or another to such an extent that the rental operation has gone beyond the mere rental of real property,” and that, accordingly, other factors such as “[t]he size or number of properties being rented” and “the extent to which their management or supervision occupies the owner's time” are not “to be taken into account in determining if the operation is a business.” ...

Summary of 8 October 2021 APFF Roundtable, Q.17 under s. 120.4(1)- arm’s length capital – (c). ...

X’s will – which provided the same terms as described above. Here, since the shares held in the trust were not acquired by it as a consequence of Mr. ...

8 November 2021- 10:42pm CRA indicates that s. 7(1.3) does not preclude a gain arising on a short sale to fund an employee stock option exercise Email this Content An employee, who engages in a short sale transaction to finance the exercise of stock options on the shares of the individual’s employer, short sells identical shares borrowed from a third-party lender and uses the short sale proceeds to inter alia fund the option exercise – and then uses the shares acquired on exercise to cover the short position. ...

CRA indicated that the current use test established under s. 20(1)(c) was relevant in this context – and that, under this test, there was a reasonable argument that the current use of borrowed money was linked to the Mergeco shares and that, to the extent that there was a reasonable expectation that FA Holdco would receive dividends on those shares, the use test would be met after the merger. ...

., an inferred double supply) – based on its confidently-expressed views that the manager’s appointment “does not negate the general partner’s responsibilities and fiduciary duties to the limited partnership” and that “the general partner is the only person with authority to implement any advice provided by a third party manager.” ...

., from Holdco 1 and Holdco 2), so that s. 125.7(4)(c) was not available – whereas it would have been available if it instead had been dealing with them at arm’s length. ...

Summaries of CPA Canada, “Uncertain Tax Treatments (“UTT Proposals”),” 5 April 2022 Joint Committee Submission under s. 237.5(1) – reportable uncertain tax treatment, reporting corporation, s. 237.5(2) and s. 237.5(8). ...

Note that the s. 211.17 prohibition applies to rebates etc. of tax which was required to be collected – so that a s. 261 rebate might not be available if the recipient indeed was registered- but failed at the time to provide satisfactory evidence of such registration to the non-resident. ...

Summary of 2021 Ruling 2020-0863171R3 under s. 55(1) – distribution. ...