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Current CRA website

T2 Corporation – Income Tax Guide – 2024

T2 Corporation – Income Tax Guide – 2024 From: Canada Revenue Agency T4012(E) Rev. 24 The CRA's publications and personalized correspondence are available in braille, large print, etext, and MP3. ... La version française de ce guide est intitulée Guide T2 – Déclaration de revenus des sociétés. ... Table of contents Footnote 1 What's new Before you start Chapter 1 – Page 1 of the T2 return Identification Chapter 2 – Page 2 of the T2 return Attachments Information schedules and forms Calculation schedules Chapter 3 – Page 3 of the T2 return Attachments Additional information Calculating net income or loss Losses How to complete Schedule 4, Corporation Loss Continuity and Application Taxable income Chapter 4 – Page 4 of the T2 return Small business deduction Chapter 5 – Page 5 of the T2 return General tax reduction Chapter 6 – Pages 6 and 7 of the T2 return Refundable portion of Part I tax Refundable dividend tax on hand Dividend refund Chapter 7 – Page 8 of the T2 return Part I tax Chapter 8 – Page 9 of the T2 return Summary of tax and credits Federal tax Provincial and territorial tax Other credits Refund or payment Payment of balance owing Direct deposit request Mandatory electronic filing for tax preparers Certification Language of correspondence Related forms and publications List of federal and provincial or territorial corporation schedules and forms Digital services Handling business taxes online Electronic payments For more information If you need help Direct deposit Forms and publications Electronic mailing lists Teletypewriter (TTY) and Video Relay Service (Canada VRS) users Formal disputes (objections and appeals) Service complaints Reprisal complaints Due dates Non-resident corporation enquiries Index Footnotes Footnote 1 For more detailed content listings, see the first page of each chapter. ...
News of Note post

Rémillard – Federal Court of Appeal finds that the CRA records transmitted to the Federal Court Registry were open to the public absent a specific confidentiality order

After agreeing with Pamel J below that such documents were part of the court file and thus accessible to the public under Rule 26 unless a confidentiality order was obtained, Montigny JA went on to reject the taxpayer’s submission (in reliance on Gernhart) that making the certified record public as a matter of course violated section 8 of the Charter, stating: Anyone engaging the courts in an action … must expect that large parts of his or her private life will become publicly accessible. … Far from transmitting confidential information without his consent and without informing him, it was rather at Mr. Rémillard's own request that the Minister transmitted the relevant documents to the Court Registry. … … Mr. Rémillard could have … requested the Court to issue an order to protect the confidentiality of certain information contained in the documents transmitted. ...
News of Note post

Glencore – Tax Court of Canada finds that a break fee was income from a business

In fact, another public company (“Inco” – the 25% minority shareholder) made a subsequent offer that was accepted by DFR, thereby triggering the payment by it of the break fee. ... Falconbridge was carrying on its business when it negotiated the Merger … Agreement[s], … which provided for the fees in dispute. … The … Fees were ancillary business income received by Falconbridge in the course of earning income from business. ... The Queen, 2021 TCC 63 under s. 9 – compensation payments. ...
News of Note post

Caisse Desjardins de Limoilou – Quebec Court of Appeal finds that a mortgagee’s prescribed security interest was reduced under Reg. 2201(2)(a) by the shareholders’ guarantee

Gagné JCA stated: First, the ordinary meaning of the words "rights of the secured creditor …" refers to all the economic rights of the secured creditor securing the obligation. There is nothing in the text of [Reg.] 2201(2)(a) … to limit these rights to the real property rights of the secured creditor [as argued by the Caissse]. … Second, the legislator was careful to add "including guarantees …” … The word "guarantees" must be taken in its broad sense, which includes suretyship. … Third, the [Finance] Explanatory Notes to the Regulations support this interpretation. … In rejecting a further argument of the Caisse that the Reg. was contrary to “the rule prohibiting the granting of pure discretion by Regulation,” she stated that the Reg. was not purely discretionary and, in fact, its meaning “can easily be determined by applying the modern method of interpretation.” ... Caisse Desjardins de Limoilou, 2020 QCCA 1612 under Reg. 2201(2)(a) and Statutory Interpretation – Regulations/Statutory Delegation. ...
Technical Interpretation - External summary

7 November 1994 External T.I. 9400965 - U.S. REAL PROPERTY INTEREST & FTC (5638-2) -- summary under Article 24

REAL PROPERTY INTEREST & FTC (5638-2)-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 FTC for U.S. ... Income Tax Convention …, the U.S. has the right to tax Mr. A's gains on the disposition of his Canco's shares, as described … above. ... As a result … Mr. A would qualify to claim a foreign tax credit under subsection 126(1) … in respect of [such] U.S. tax liability…. ...
Current CRA website

Offshore Compliance Advisory Committee – Agenda – August 3, 2016

Offshore Compliance Advisory Committee – Agenda – August 3, 2016 Wednesday August 3, 2016 9:00 a.m.- 4:30 p.m. ...
News of Note post

Chad – Tax Court of Canada finds that the presumption that commercial activity is in pursuit of profit and, thus, a source, was rebutted where there was no real interest in generating profit

The documentary evidence … does not give any indication that Mr. Chad … intended, in conducting the FX Activities, to achieve a profit/loss amount great enough to offset the $240,000 fee, which was a significant expense …. Thus … the intention of Mr. Chad … in implementing the Trades, was not to earn a profit …. ... The King, 2024 TCC 142 under s. 3(1) – business, and General Concepts- Sham. ...
Conference

18 June 2015 STEP Roundtable Q. 2, 2015-0572091C6 - 2015 STEP – Q2 – Meaning of Graduated Rate Estates

18 June 2015 STEP Roundtable Q. 2, 2015-0572091C6- 2015 STEP – Q2 – Meaning of Graduated Rate Estates CRA Tags 248(1) Principal Issues: CRA comments requested on meaning of graduated rate estate, including what property is included & what happens when there are 2 wills. ...
Decision summary

Blais v. MNR, 92 DTC 1497 (TCC) -- summary under Payment & Receipt

MNR, 92 DTC 1497 (TCC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment references funds transfer A taxpayer was ordered in 1984 to retain arrears of alimentary allowance that had accumulated from March 1983 onward to be applied against an amount owing to him by his estranged wife. In finding that the alimentary allowance was not "paid" by him for purposes of s. 60(b), and was not "received" by her for purposes of s. 56(1)(b), Garon J. stated (p. 1499): "... ...
TCC (summary)

Aprile v. The Queen, 2005 DTC 585, 2005 TCC 216 (Informal Procedure) -- summary under Payment & Receipt

The Queen, 2005 DTC 585, 2005 TCC 216 (Informal Procedure)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payments in kind Bell J. rejected the Crown's submission that the taxpayer can only make a deduction under s. 8(1)(i) for amounts paid in cash or by cheque with proof of payment, and found that the taxpayer was entitled to a deduction under s. 8(1)(I)(ii) for snowmobiles, motorcycles and gasoline that he had purchased for his sons as payment for their services in performing mailings to 2,500 people on five different occasions in the year. ...

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