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. … In its review, the Income Tax Rulings Directorate will have to consult internal stakeholders and the whole process may take some time. ...

. … Since a “branch” of a non-resident corporation is not a separate legal entity from the non-resident corporation, payments to a Canadian branch of a non-resident corporation made in respect of services provided in Canada are subject to Regulation 105 withholding.... ...

11 March 2024 External T.I. 2022-0939331E5- Workers’ Compensation Settlement-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) no withholding on WSIA worker’s compensation CRA noted that since s. 56(1)(v) requires an income inclusion for "compensation received under an employees’ or workers’ compensation law … of a province in respect of an injury,” compensation received by the estate of an injured worker pursuant to the Ontario Workplace Safety and Insurance Act was includible in its income (and deductible in computing its taxable income.) ...

., a provision in the governing Act providing that a SARL “is created by (one or more) persons that agree, through an agreement, to contribute, to an activity, cash, or in-kind or services assets for the purpose of sharing profits or enjoying revenues that may derive therefrom” – but, overall, its attributes were closer to those of a Canadian corporation than of a partnership. ...

CRA indicated that to the extent that the Government Assistance received by Aco was in respect of the acquisition of depreciable property (or land), s. 13(7.1) (or s. 53(2)(k)) will deem that amount to reduce the capital cost of the depreciable property (or land) – without any inclusion under s. 12(1)(x) pursuant to s.12(1)(x)(vi) and (in contrast with s. 13(7.4) or 53(2.1)) without any election required. ...

In the case of the gift, CRA noted that although s. 69(1)(c) would deem the building’s cost to the resident to be its FMV of $1.4 million, the ½ step-up rule in s. 13(7)(e)(ii) would reduce the capital cost of the building to the resident to $1.2 million, so that the starting undepreciated capital cost of the building would also be that amount. ...

4 June 2024 STEP Roundtable Q. 5, 2024-1003541C6- Post-Mortem Planning and GAAR-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) no GAAR issues re conventional pipelines and s. 164(6) loss carrybacks When asked to comment on post-mortem pipelines and s. 164(6) loss carryback plans in light of the amended version of GAAR, CRA referred to its statement in 2023-0987941I7 that it “does not consider the use of a pipeline transaction as a means to preserve the capital gain arising on the death of a shareholder while limiting double taxation on the subsequent distribution of Opco’s assets to be a … [GAAR] abuse” and went on to state: As for the s. 164(6) loss carrybacks, the Directorate is not aware of any specific concerns relating to the potential application of the amended GAAR in circumstances involving the carryback of losses under s. 164(6), and has not provided any general guidance in this respect. ...

. … [A]ny change in the value of such an investment does not constitute an amount that was expended during the period in which the loss occurred. ...

However, in most cases, because of the nature of the expense, it may be difficult to completely separate the entertainment aspect from the strictly professional aspect of the event …. ...

. … [Furthermore] the pit is permanently fixed to the ground, which constitutes a permanent foundation. ...