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Required homogeneity of cost pools Appropriate costs pools … If direct inputs are grouped together for ITC allocation purposes, all the direct inputs within the cost pool must: be for use to the same extent for the purpose of making taxable supplies for consideration if the inputs in the pool are tracked (e.g., a pool of inputs that are tracked cannot include an input that is used 2% for the purpose of making taxable supplies for consideration with an input that is used 30% for the purpose of making taxable supplies for consideration); be allocated using the same, appropriate, allocation base if the inputs in the pool are allocated using causal allocation; apply to the same portion of the business if the input is allocated using input-based allocation; and apply to the same portion of the business and use the same appropriate output measures (e.g., revenue) if the input is allocated using output-based allocation. ...

VII: extended relief for Canadian residents exercising their U.S. employment at home in Canada for COVID reasons (with Treaty-reporting alternative) Where as a result of the travel restrictions, Canadian-resident individuals have been forced to perform their duties for a U.S. employer from their Canadian home and (for the initial relief period) their employer received a CRA letter of authority (to reduce the Canadian source deductions at source to reflect the available foreign tax credit), as an administrative concession, CRA will treat the employment income from the U.S. employer for 2020 that was subject to U.S. withholding as having a U.S. source – so that those individuals can file their tax returns as in prior years and claim a foreign tax credit for the U.S. taxes. ...

CRA, on a case-by-case basis, has been prohibiting, pursuant to a s. 147.1(5) condition, employers and members from contributing to a money purchase provision of an IPP or to a designated plan if actuarial surplus under the defined benefit provision of the plan is more than the surplus limit – so that any required contributions to the plan’s money purchase provision are permitted only if they are made from the surplus (as permitted by Reg. 8502(k) and s. 147.3(4.1).) ...

. … [U]nder subsection 141.02(8), the following rules apply: the extent to which the consumption or use of the residual input is for the purpose of making taxable supplies for consideration is deemed to be equal to the prescribed percentage for the prescribed class of financial institution the extent to which the consumption or use of the residual input is for purposes other than making taxable supplies for consideration is deemed to be equal to the difference between 100% and the prescribed percentage for the prescribed class of financial institution (that difference being 88% for banks, 90% for insurers and 85% for securities dealers) the extent to which the residual input is acquired by the qualifying institution for the purpose of making taxable supplies for consideration is deemed to be equal to the prescribed percentage for the prescribed class of financial institution the extent to which the residual input is acquired by the qualifying institution for purposes other than making taxable supplies for consideration is deemed to be equal to the difference between 100% and the prescribed percentage for the prescribed class of financial institution (that difference being 88% for banks, 90% for insurers and 85% for securities dealers) for the purpose of determining an ITC in respect of the residual input of the qualifying institution, the description of Element B of the formula in subsection 169(1) is deemed to be equal to the prescribed percentage for the prescribed class of financial institution Required to follow the usual rules for exclusive and excluded inputs A qualifying institution will still generally be required to follow the rules in subsection 141.02(6) in respect of each exclusive input and use a specified method pursuant to subsection 141.02(14) for each excluded input. ...

A taxpayer seeks to avoid the s. 18(19) straddle-transaction rules by acquiring a partnership interest in a partnership that had an accrued loss and gain on the two legs of an FX straddle, with the closing of such acquisition being immediately preceded by the closing out by the partnership of the gain leg so that such gain is allocated to the vending partner pursuant to s. 96(1.01) – and with the loss leg realized after the acquisition and allocated to the taxpayer. ...

Example 8 A municipality provides a transfer payment to an NPO to build a sports facility on municipal land (the primary purpose is to acquire the facility – there is a direct link). ...

Voluntary disposition of Class 14.1 property generally not eligible for replacement property rules. 1.46 … One of the characteristics of a former business property is that the property is real or immovable property or an interest therein. ...