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For proposals filed under Division 1 of the … BIA … the CRA is offering a waiver of the default pursuant to section 62.1 of the BIA and granting a deferral of payments to the estate up to September 1, 2020. ...

27 March 2023 CRA News Release, Underused Housing Tax penalties and interest waived-- summary under Subsection 48(1) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Underused Housing Tax Act- Section 48- Subsection 48(1) UHTA returns will not attract late-filing penalties or interest if received by October 31, 2023 CRA announced: … CRA … understands that there are unique challenges for affected owners in the first year of the Underused Housing Tax Act (UHTA) administration. ...

Adoption of economic substance Canada Trustco unfortunately had not adopted the Finance statement accompanying GAAR’s introduction that it “would apply together with the … other provisions [of the Act] to require economic substance in addition to literal compliance with the words of the Act” (p. 21). ... In this regard [:] … First, it is necessary to define economic substance so that it is possible to determine when it is lacking. ... An interpretive rule could provide in the GAAR context that “tax benefits are intended to be conferred only in the context of transactions with economic substance” – although it would be necessary to "ensure that transactions which appear to lack economic substance but are not objectionable from a policy perspective” are excepted (p. 28). ...

Example of application to services provided under active direction of sub 2.69 … Example 3 – Central paymaster rules Corporation A provides services to …[its subsidiary] Corporation B … of a type that could reasonably be expected to be performed by employees of the Corporation B in the ordinary course of its business. In this regard, Employees of Corporation A report to a permanent establishment of Corporation B, receive direction from Corporation B’s corporate structure, and all or substantially all of the Employees’ economic activity is for the benefit of Corporation B. … For the purposes of Part IV of the Regulations the salaries and wages of Corporation A’s Employees would be attributed to Corporation B’s salaries and wages paid in the year. ...

When asked to comment on this position being contrary to Fraser International, which held that a private college was “affiliated” with a university, and hence qualified as a “university”, even though the parent organization (Simon Fraser University) did not grant degrees to graduates of that college, CRA stated: Th[is] lack of reference to … Fraser International … is an oversight on our part. We thank you for bringing this to our attention. … [T]he CRA is reviewing Memorandum 20-3 to include additional information on whether an organization operating a college affiliated with a university qualifies as a university …. ...

T4068(E) Guide for the Partnership Information Return (T5013 Forms)-- summary under Subsection 96(1.01) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(1.01) S. 96(1.01) special allocation is made at the end of the regular partnership taxation year Line 350 – Other adjustments … Paragraph 96(1.01)(a) does not require that partnership income or loss be calculated immediately after a member leaves the partnership. ...

. … Additional information on procedures for refunds and adjustments of the GST/HST may be found in … Memorandum 12-2 …. ...

CRA indicated that it agreed with the conclusion reached as inter alia being consistent with the single supply doctrine and given that: The administrative arrangement, which permits dentists to claim ITCs based on a percentage of general operating expenses, is contradictory to the ITC provisions of the … ETA …. ...

. … CRA … has resolved a file regarding a hybrid mismatch arrangement involving the deduction of non-arm’s length interest in a series of transactions that included a forward subscription agreement (outlined in the diagram below) on the basis that paragraphs 247(2)(b) and (d) of the Income Tax Act and transfer pricing penalties applied. ...

CRA commented: A determination of the LP’s primary purpose would generally reflect its main or fundamental purpose at the time it was established – and may be reassessed later on. The … primary purpose [would not] be affected solely by short-term changes in the value of investments due to market shifts. In addition, the … statement … is not in itself sufficient to exclude the LP from being an ILP. ...