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Alexandra MacLean, "CRA Audits of Large Corporations- The view from ILBD" under Responses to recent adverse decisions – Wild, 27 November 27 2018 CTF Annual Conference.-- summary under Subsection 245(2) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(2) GAAR should not be applied until realization of a tax savings Wild found that transactions that boosted the paid-up capital of shares held by the taxpayer should not be addressed by applying the general anti-avoidance rule to reduce the PUC of those shares, but that there instead could only be a GAAR abuse when such PUC was distributed to him. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.4-- summary under Subparagraph 156(4)(b)(ii) Summary Under Tax Topics- Excise Tax Act- Section 156- Subsection 156(4)- Paragraph 156(4)(b)- Subparagraph 156(4)(b)(ii) CRA will deny a request for a late-filed ETA s. 156 election where not all returns have been filed Respecting a query on late-filed ETA s. 156 elections, CRA stated: Under administrative tolerance, the CRA may consider a request to accept a late-filed election. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.8-- summary under Subsection 191(3) Summary Under Tax Topics- Excise Tax Act- Section 191- Subsection 191(3) supplies acquired prior to self-supply time generate ITCs even if only invoiced later Where a builder was invoiced, after the time that it self-assessed for the fair market value of a newly-constructed multiple unit residential complex (at the time of substantial completion and first tenant occupancy) for work done before that time, CRA explained the availability of an input tax credit therefor on the basis that, by virtue of s. 133: where a builder of a MURC agrees to acquire property or a service for consumption or use in constructing the MURC, the supply of the property or service is generally considered to be made to the builder at the time that the agreement is entered into (that is, the builder is considered to be the recipient of the supply at that time). ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.10-- summary under Subsection 296(2.1) Summary Under Tax Topics- Excise Tax Act- Section 296- Subsection 296(2.1) ss. 296(2.1) and 262(2) technically prohibit adjustment to already-filed NRRP rebate claim CRA is assessing to increase the amount of GST/HST self-assessed by a builder under ETA s. 191(3) on substantial completion and first occupancy of a rental residential complex. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.18-- summary under Subsection 221(2) Summary Under Tax Topics- Excise Tax Act- Section 221- Subsection 221(2) CRA may consider assessing the purchaser directly where the vendor was misled in relying on s. 221(2) Joint venture participants, who had not made a joint venture election, purchased real estate collectively through a representative who was registered for GST/HST purposes. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.18-- summary under Paragraph 296(1)(b) Summary Under Tax Topics- Excise Tax Act- Section 296- Subsection 296(1)- Paragraph 296(1)(b) CRA might assess purchaser directly where vendor had innocently relied on s. 221(2) Joint venture participants, who had not made a joint venture election, purchased real estate collectively through a representative who was registered for GST/HST purposes. ...

Frequently Asked Questions – Temporary Wage Subsidy for Employers 30 March 2020 CRA Webpage-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) COVID-19 wage subsidy includible in income The subsidy equals 10% of the remuneration paid between March 18, 2020, and June 20, 2020, to a maximum of $1,375 per employee and of $25,000 per employer (with associated CCPCs not being required to share the $25,000 maximum). ...

Mandatory disclosure rules – Guidance, 15 August 2024 CRA Webpage-- summary under Reportable Uncertain Tax Treatment Summary Under Tax Topics- Income Tax Act- Section 237.5- Subsection 237.5(1)- Reportable Uncertain Tax Treatment Reportable uncertain tax treatments (RUTTs) RUTT restricted to matters reported on Canadian returns "An uncertain tax treatment is a tax treatment used or planned to be used in an entity’s Canadian income tax filings for which there is uncertainty over whether the tax treatment will be accepted as being in accordance with tax law. ...

GST/HST Memorandum 3-3-5 “Place of Supply in a Province – General Rules for Intangible Personal Property” January 2025-- summary under Paragraph 6(2)(c) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 6- Subsection 6(2)- Paragraph 6(2)(c) Example 10 An Ontario company supplies a Quebec company with a copyright for $500 that can only be used in Ontario and Nova Scotia and, in the ordinary course of business, obtains a Quebec address of the recipient. ...

GST/HST Memorandum 3-3-5 “Place of Supply in a Province – General Rules for Intangible Personal Property” January 2025-- summary under Clause 8(b)(i)(A) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 8- Paragraph 8(b)- Subparagraph 8(b)(i)- Clause 8(b)(i)(A) Example 15 An Ontario company licenses software to a Quebec company for use throughout Canada with the only business address of the recipient received in the ordinary course of business being an address in Quebec, which is the place of supply. ...