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2020 IFA-YIN Seminar on COVID-19 Guidelines, Q.3 and Q.4-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) no dispensation from source deductions for non-resident employers whose employees work from Canada due to COVID travel restrictions If an individual is not ordinarily resident in Canada, but is in Canada due to Travel Restrictions or otherwise due to public safety concerns relating to COVID-19, and works remotely (for their non-resident employer) from Canada, would the employer, if it has no Canadian ties, now be subject to withholding obligations in Canada – including in the situation where it did not consent to this Canadian nexus? ...

The ancillary documents indicate this targets a cash-basis taxpayer; what about one who uses accrual accounting, but deviates from GAAP in some other respect – for example, a taxpayer which does not net discounts against revenues, instead reporting them as an expense, or nets bad debts against revenues. ...

Excise and GST/HST News- No. 108 September 2020-- summary under Paragraph 2(e) Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part I- Section 2- Paragraph 2(e) CRA’s existing policy re drugs with mixed substances is consistent with Patterson Dental [Patterson Dental held] that the supply of epinephrine in combination with an analgesic in the appellant’s solutions was not a single supply containing a taxable element and a zero-rated element, and was therefore not zero-rated …. ...

. … 3. The purpose of the investigation of a site may be to determine whether the land is physically suited for the planned building or other structure or whether such a building or structure would be economically viable on that site, or it may be a combination of those two objectives. ...

Under the proxy method, its qualified expenditures include only Sarah’s salary for the period, but are grossed-up by the 55% prescribed proxy amount, and that total is reduced by all and 30%, respectively, of the CEWS received by the corporation in relation to their respective salaries for that period. ­­­­­­­­­­­­­­­­­­­­ ...

. … Election on class-by-class basis If you supply different classes of memberships that do not have the same fees, rights and privileges as other classes, you can make this election on a class-by-class basis. ...

The requirements applicable to a spouse trust in subsection 70(6.1) are the same as those applicable to a spouse trust in subsection 70(6), with the exception that subsection 70(6.1) does not contain any residency requirements …. 1.61 Alternatively, the deceased taxpayer’s legal representative may file an election under subsection 70(6.2) to have subsection 70(5.4) apply to the deceased’s NISA Fund No. 2. ...

Treaty for US residents to access s. 70(6) rollover re TCP 1.63 … [F]or the rollover treatment in subsection 70(6) to apply on the transfer or distribution of property to a spouse trust, the taxpayer must be resident in Canada immediately before death. ...

GST/HST Notice 323, Proposed GST/HST Treatment of Assignment Sales, May 2022-- summary under Section 192.1 Summary Under Tax Topics- Excise Tax Act- Section 192.1 Treatment of assignment sales (of an agreement with a builder for a new home) under pre-s. 192.1 rules (p. 1) Under the current GST/HST rules, an assignment sale … made by an individual is generally taxable if the individual had originally entered into the agreement of purchase and sale with the builder for the primary purpose of selling their interest in the real property. ...

. … Accordingly, no GST/HST is applicable in respect of the taxable supply made by a solo miner that performs a mining activity and receives a mining payment before February 5, 2022. ...