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Although the Commission (which effectively was her agent) had received the RRSP proceeds in an earlier taxation year, it was not to be included in her income until the subsequent year when she was ascertained and received the amount from the Commission,-on the basis of the “longstanding position … that the CRA must … rely on the facts as they exist at the end of the taxation year” – and the essential basis for income inclusion was not identified until the subsequent year. ... The benefit to be recognized by her under s. 146(8) was to be grossed-up by the amount of fees that were deducted by the Commission and treated by the governing unclaimed property legislation as an obligation of her – and such fees were not deductible by her as they were not “incurred for the purpose of earning income.” ... Summaries of 13 August 2020 External T.I. 2019-0802891E5 F under s. 146(1) – benefit – (a), s. 146(8), s. 146(4)(c) and General Concepts – Payment and receipt. ...

All but the units of the 175 smallest unitholders (holding at least 100 units) will be acquired in the first tranche – and then, 60 seconds later, the units of the remaining 175 unitholders will be acquired. ... Roughly ¼ of the REIT’s properties are U.S. properties which are held in a U.S. private REIT subsidiary of a B.C. holding company (“CanCo SPV”) that, in turn, is held by the REIT. ... Summary of Pure Industrial REIT Circular under Mergers & Acquisitions – REIT/Income Fund/LP Acquisitions – Trust Acquisitions by Corporations. ...

Summary of 1 September 2020 External T.I. 2019-0832221E5 under s. 146.1(1) – subscriber – (a). ...

Summaries of 23 May 2023 External T.I. 2017-0713011E5 F under s. 6(2) – A(a) and s. 248(1) – automobile – (e)(i). ...

Neal Armstrong Summary of 30 October 2024 Internal T.I. 2023-0996541I7 under s. 248(1) – disposition – (a) and s. 54 – proceeds of disposition. ...

Pizzitelli J applied the single supply doctrine in finding that the predominant element of what was being supplied by the dealer was an exempt supply of arranging for the insurance – and that the exclusion in (r.4) of the definition of an exempt financial services for promotional and various administrative services did not apply. ... Summary of Excise and GST/HST News- No. 106 June 2019 under ETA – s. 123(1) – financial service – para. ...

13 April 2021- 10:39pm CRA comments on when utilities can be added to rent for CERS purposes and notes CERS/CEWS similarity for computing revenue reduction Email this Content The definition of “qualifying rent expense” for purposes of the CERS (rent subsidy) refers to “rent … including … regular instalments of operating expenses, such as insurance, utilities and common area maintenance expenses, customarily charged to the lessee under a net lease.” ... Summaries of 23 March 2021 TEI Roundtable, 2021-0879631C6 under s. 125.7(1) – qualifying rent expense – (a)(i)(C)(II), rent subsidy percentage and s. 125.7(2.1). ...

Per s. 95(2)(f.11)(ii)(D), where a portion of a taxpayer’s IFE for a taxation year is denied under s. 18.2(2), the same proportion of a CFA’s relevant affiliate IFE is similarly denied for purposes of computing its FAPI for the relevant taxation year – but, unlike the treatment of restricted IFE (which may be carried forward to a subsequent year depending on the availability of excess capacity), the denied deduction for purposes of computing FAPI of a foreign affiliate apparently cannot be carried forward. ... The EIFEL revisions have removed the requirement that cumulative unused excess capacity could only be transferred between eligible group corporations that have the same functional currency – and transfers of capacity respecting a “fixed interest commercial trusts” (e.g., most REITS) can now be made. ... Summaries of EY, “Revised EIFEL proposals,” Tax Alert 2022 No. 43, 10 November 2022 under s. 18.2(1)- relevant affiliate interest and financing expenses, interest and financing revenues, adjusted taxable income – B- (h), s. 18.2(4), s. 95(2)(f.11)(ii)(A), s. 95(2)(f.11)(ii)(D), Reg. 5907 – earnings – (b), s. 18.21(1) – group ratio, s. 18.21(2)(a). ...

Summaries of 25 May 2018 External T.I. 2018-0761601E5 under s. 120.4(1) – excluded shares – para. (b), excluded shares – subpara. (a)(i), excluded amount – subpara. (e)(ii) and s. 120.4(1.1)(a). ...

Public company PUC is useless – except when it is useful. Neal Armstrong. Summary of Kinder Morgan Canada Circular under Spin-offs & Distributions – ss. 84(4.1)(a) and (b) distributions of proceeds. ...