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. … 6. While cases may arise where interest is computed retroactively, no penalty will be imposed retroactively as a result of an amendment to Part IX of the Act. ...

. … An independent contractor for services must also be distinguished from an agent. ...

FAQ- Deferral of GST/HST Tax Remittances: CRA and COVID-19 20 April 2020 CRA Webpage (as amended on June 29, 2020)-- summary under Section 280.1 Summary Under Tax Topics- Excise Tax Act- Section 280.1 no penalties for late-filing GST/HST returns on June 30, 2020 CRA announced that although “The deadline for businesses to file their [GST/HST] returns is unchanged … the CRA won’t impose penalties where a return is filed late provided that it is filed by June 30th.” ...

Specified person – In addition to giving facts and reasons for objecting, a specified person has to describe each issue and specify the relief the person wants for each one. ...

The co-ownership interest of D is exempted under s. 6(1)(g) – but not that of C. ...

CCRA ruled: The insurance claim payment that relates to the indemnification of an account receivable that became a bad debt does not constitute the recovery of the bad debt for the purposes of subsection 231(3) …. ...

S3-F3-C1- Replacement Property-- summary under Paragraph 44(1)(c) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(1)- Paragraph 44(1)(c) Replacement property can be acquired at any time after notice of intention to take 1.11 Where … a former property was taken under statutory authority, the replacement property can be acquired at any time after a taxpayer receives notice of an intention to take the property under statutory authority and before the time noted in [s. 44(1)(c)]. ...

Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025-- summary under Subsection 15(2.17) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.17) Overview 1.18 … In very general terms, where the conditions set out in subsection 15(2.16) are met, subsection 15(2.17) deems that the particular corporation or partnership made a loan to the borrower for the purposes of sections 15 and 80.4, in an amount equal to the funding indirectly provided. ...

IC72-17R6 "Procedures concerning the disposition of taxable Canadian property by non-residents of Canada – Section 116" September 29, 2011 ...

29 July 1992 Memorandum (Tax Window, No. 21, p. 4, ¶2037)-- summary under Subsection 249(4) Summary Under Tax Topics- Income Tax Act- Section 249- Subsection 249(4) Two unrelated individuals each holding ½ of the shares of a corporation will not be considered to act in concert simply because the consent of both is required before the corporation can undertake any action. ...