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The reason is that (a)(ii) of the ERDTOH definition only adds the Part IV tax if it generated a dividend refund to the connected payor out of its ERDTOH – and since the connected payor by assumption had not yet transitioned to the ERDTOH/NERDTOH regime, this would not be possible. ...

“[I]t is not necessarily the case that a qualifying property of an eligible entity will always conform to its legal title” – for example, the leasehold interest of a commercial tenant may represent only a portion of the legal title of the property. ...

Accordingly … business interruption insurance proceeds would generally be included in qualifying revenue and would generally not be considered an extraordinary item. ...

. … Although a leasing agreement is often referred to as a financing agreement, the CRA believes that the leasing agreement cannot be considered a true loan. ...

After indicating that where a taxation year has already been assessed on the basis of a fiscal period end, the Act does not have any provision that allows a reassessment to change the FPE, the Directorate went on to state: [T]he … [preamble] wording of subsection 249.1(1) indicates that the purpose of specifying a particular period of time as a fiscal period is that a corporation can choose, within the parameters specified under the subsection, a FPE for preparing its accounts for the purposes of assessment. ...

Conversely, if it was determined that TDH did not carry on a business, the excluded share exception would not apply – but s. ...

Conversely, if it was determined that the corporation did not carry on a business, the excluded share exception would not apply – but s. ...

Provided that … Mr. A is regarded as a tax resident of XXXXXXXXXX by virtue of Article 4(1) of the Treaty, the capital gain realized by Mr. ...

If a Treaty has no time-limits itself, then the usual domestic limits apply, for example, under s. 152 – again, subject to any changes provided in Bill C-20, that extend those delays for periods up to six months, but no later than December 31, 2020. ...

15 September 2020 IFA Roundtable Q. 5, 2020-0853401C6- IFA 2020 Q5: TPM-17 and COVID-19-- summary under Paragraph 247(2)(a) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2)- Paragraph 247(2)(a) Canadian governmental COVID assistance likely will not reduce cost under cost-plus transfer-pricing methods TPM-17 provides that the cost base should not be reduced by government assistance unless there is reliable evidence that arm’s length parties would have done so – so that it generally is presumed that the Canadian taxpayer will keep the assistance. ...