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It was “Rulings’ view that allowing subsection 220(2.1) to waive a taxpayer’s requirement to file an election not listed in Regulation 600 would negate the specific intention of Parliament in limiting late elections to only those that are prescribed in [Reg.] 600” – and, in any event, the CIF provision was not a provision of the Act itself, as required by s. 220(2.1). ...

29 December 2022- 11:08pm The proposed version of s. 85.1(4) is overly broad Email this Content The current version of s. 85.1(4) avoids deferral of the capital gain that would otherwise be realized on the outright sale of a directly held FA (the first affiliate) through transferring it under s. 85.1(3) to a second affiliate, which then sells the first affiliate shares to a subsequent acquiror – where the first affiliate shares are excluded property so that such sale occurs on a deferred basis. ...

Summary of 2021 Ruling 2020-0852541R3 F under s. 55(1) – distribution. ...

The scholarship exemption for an award received by a PT “qualifying student” is generally limited to the cost of materials related to the program, the fees paid to the “designated educational institution” (DEI) in respect of the program, and the basic scholarship exemption of $500 – whereas the full amount of the grant received by an FT qualifying student is eligible for the scholarship exemption under s. 56(3)(a) provided (in the words of CRA) “it is reasonable to conclude that the award is intended to support the individual’s enrolment in the program.” ...

Summary of 2021 Ruling 2020-0862431R3 F under s. 248(1) – disposition. ...

The test in s. 144.1(2)(e)(i)(A) requires that the “trust … contains at least one class of beneficiaries where the members of the class represent at least 25% of all of the beneficiaries of the trust who are employees of the participating employers under the trust.” ...

., generally, it was for occupancy as a place of residence of the lessee for over one month) or 6.1 (where there was an exempt sublease), the portions of the upfront payments that were “attributable” to such lease intervals would be exempted – whereas the portion of the upfront payment attributable to any subsequent lease intervals where the use became taxable would be subject to GST/HST. ...

Summary of 2021 Ruling 2021-0904311R3 F under s. 55(1) – distribution. ...

CRA then stated: Following [Poulin], we accept … that an amount for damages may be deducted in a year in which a taxpayer no longer carries on business, since the taxpayer is presumed not to have ceased carrying on business for as long as the taxpayer is engaged in carrying through on acts committed to by the taxpayer in the course of the business, even if, at the time the amount is deducted, the taxpayer is no longer transacting and can no longer attend to the taxpayer’s customers. ...

It could, however, assess the resident beneficiary for an amount not exceeding $100,000 on December 31, 2022 given that the conditions in s. 94(7) were by assumption satisfied for the 2020 year – and this was so even if s. 94(3) had ceased to apply to the trust for its 2021 or 2022 taxation year. ...