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25 June 2020- 12:06am CRA establishes 3 conditions for there to be an extraordinary item for CEWS purposes Email this Content Before concluding (in the context of provincial support payments to childcare centres to assist them during the COVID-19 pandemic) that it would “generally consider emergency government assistance … directly related to COVID-19 to be an extraordinary item,” so that such assistance would generally be excluded as an extraordinary item from “qualifying revenue” for CEWS (wage subsidy) purposes, CRA stated: Generally, we would expect extraordinary items to meet all three of the following characteristics: a) Not be expected to occur regularly or frequently within several years Grants or other government assistance that an entity is eligible to receive on a regular or reoccurring basis would not meet this criteria. b) Not typical of the normal activities or risks inherent in the normal operations of the entity … c) Primarily out of the control of owners or management …. ... Summary of 6 May 2020 Internal T.I. 2020-0846711I7 under s. 125.7(1) – qualifying revenue – (c). ...

Summary of preliminary prospectus of Trisura Group under Spin-offs & Distributions – Taxable dividends-in-kind- Subsidiary distribution. ...

When asked about how much FATCA information had been transmitted to the IRS and what its response was, CRA stated: As of April 1, 2019, the CRA had sent over 700,000 records to the … IRS … under the [FATCA program] for the 2017 tax year. ...

Summary of 27 October 2020 CTF Roundtable, Q.6 under Treaties – MLI – Art. 7(1). ...

Summary of 11 October 2022 External T.I. 2020-0856421E5 under s. 125(7) – AAII – para. ...

Summary of 26 September 2023 External T.I. 2023-0984971E5 under s. 248(1) – disposition – (j). ...

Summaries of 10 October 2024 APFF Financial Strategies & Instruments Roundtable, Q.9 under s. 122.92(1) – qualifying relation, s. 252(2)(g), s. 54 – principal residence, and s. 122.92(1) – eligible individual. ...

Each year’s ATI is reduced by the non-capital loss and net capital loss generated for the current year – yet if these losses are applied in a future year, there is no consequential ATI adjustment for that subsequent year (except for the partial addback of the portion of a non-capital loss that reasonably relates to the taxpayer’s net interest and financing expense). ... Summaries of PwC, “Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime,” Issue 2022-06, 15 February 2022 under s. 18.2(1) – adjusted taxable income – A, excluded entity, excluded interest, interest and financing expenses – A – para. (d), s. 18.2(2), s. 18.2(3), s. 18.2(4)(c), s. 18.21(1) – acceptable accounting standards and s. 18.21(2). ...

Finance has now issued a comfort letter stating: [W]e have no tax policy concerns with respect to the payment of investment management fees directly by the annuitant/holder of the registered plan. … Generally, the direct payment of fees results in either a net loss, or negligible gain, for the plan holder. We are therefore prepared to recommend … that paragraph (b) of the definition "advantage" … be amended [respecting 2018 and subsequent taxation years] such that it does not apply to payments by a controlling individual of a registered plan, not exceeding a reasonable amount, of fees described in paragraph 20(l)(bb) …. ... Summary of 26 August 2019 Comfort Letter- “Advantage”: Exclusion for Investment Management Fees under s. 207.01(1) – advantage – (b)(i). ...

The predominant nature of the service … is preparatory in nature to the … potential provision of a financial service, that is, the lending …. ... Summaries of 2 May 2019 GST/HST Ruling 150998 under ETA s. 123(1) – financial service – para. ...