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A corporation filing its returns using a functional currency would use that currency in measuring its qualifying revenue – but Canadian dollars would be used where the normal accounting practice is to measure in Canadian dollars. ... Additional summaries of Frequently asked questions- Canada emergency wage subsidy (CEWS) CRA Webpage 12 August 2020 under s. 125.7(1) – eligible entity- (a), eligible entity- (f), qualifying entity – (d)(ii), qualifying entity – (c)(ii), s. 125.7(1)- qualifying revenue, s. 125.7(9)(b), s. 87(2)(g.5), s. 125.7(4)(d), s. 125.7(4.1), s. 125.7(1) – eligible remuneration, s. 125.7(1) – top-up percentage, base percentage. ...

Summaries of PwC, Tax Insights: Investment limited partnerships ─ GST/HST & QST filing obligations, Issue 2020-27, May 04, 2020 under ETA s. 123(1) – ILP and s. 225.4(6). ...

2 March 2017- 11:23pm CRA requirement for disregarded LLCs to now compute their surplus under the ITA engenders complications Email this Content At the annual 2016 CTF annual conference, CRA announced that, retroactive to all FA taxation years ending after August 19, 2011, a disregarded US LLC must apply ITA rules to its surplus computations rather than using the local tax law (under the Code) – and that if this entails a switch from using US tax law, CRA would treat deductions claimed under the Code as if they had been claimed under the ITA. ... Summary of Paul Barnicke and Melanie Huynh, "Earnings of Disregarded US LLC," Canadian Tax Highlights, Vol. 25, No. 2, February 2017, p. 5 under Reg. 5907(1) – earnings – (a)(iii). ...

Summaries of Brian Kearl and Carl Deeprose, Leaving Canada's New High Tax Rate Regime: Considerations, Tips and Traps, 2016 CTF Annual Conference draft paper under s. 250(1)(a), s. 2(1), Treaties, Art. 4, s. 128.1(1)(d), Treaties – Art. 18 and s. 210(1) – designated income – s. ...

XXIX-A (3), and that under those rules and having regard to the deeming by s. 104(2) of a reference to a trust as being a reference to the trustee, the Trust controlled US Opco by virtue of its trustee (US parent) controlling US Opco – so that the Trust and US Opco were related. ... Summary of 8 September 2017 External T.I. 2014-0549771E5 under Treaties – Articles – Art. 29A. ...

First, there would be a “somersault” Plan of Arrangement under which Encana would distribute common shares, having a nominal value, of a newly-incorporated CBCA corporation (“Ovintiv”) to its shareholders and they then would exchange their Encana common shares for shares of Ovintiv – except that, in the somewhat unlikely event that the Encana shares had traded up to above U.S.$6.30 a share (presumably corresponding to an estimate of the paid-up capital of the Encana shares), the shareholders would also receive U.S.$0.25 per share of an Ovintiv note, so that the exchange would occur on a non-rollover basis unless they elected with Ovintiv under s. 85. ... Summary of Encana Proxy Statement and Ovintiv Prospectus under Other – Continuances/Migrations – Outbound continuances. ...

(f) of “Canadian exploration expense” that the expense generally has been incurred “for the purpose of determining the existence, location, extent, or quality of a mineral resource,” CRA rejected an argument that the “qualify” aspect of this test could encompass expenses for determining the economic feasibility of a deposit, such as expenses for preparing pre-feasibility or feasibility studies, stating: [E]xpenses that qualify for CEE do not … include expenses for determining the economic viability of a mineral resource if those expenses do not relate to a determination of the natural (e.g., physical, chemical or mechanical) characteristics of the mineral resource. ... Neal Armstrong Summary of 9 February 2022 External T.I. 2020-0873931E5 under s. 66.1(6) – CEE – (f). ...

. … Furthermore … Richer indicat[ed] that "in the context of section 80, the word 'settle' connotes a final and legally binding resolution that terminates or reduces the debtor’s obligations” …. ...

CRA ruled that the high interest rate paid on such deposits will not constitute an “advantage” as defined in s. 207.01(1), on the basis that the exception in (a)(v) of that definition will be met – which, in approximate terms, refers to an incentive offered in a normal commercial or investment context to “a broad class” of arm’s length persons where it is reasonable to conclude that none of the main reasons for the program is to access the registered plan exemption for “any amount in respect of the plan.” ... Summary of 2023 Ruling 2023-0979811R3 under s. 207.01(1) – advantage – (a)(v). ...

After now indicating that this question “is still under review by the CRA,” it stated: In parallel, work is underway at the …OECD … to develop the Crypto-Asset Reporting Framework …, a standardized package that will include reporting requirements to tax administrations and exchange of information procedures related to taxpayers’ transactions with crypto-asset service providers. … A public consultation meeting will be held at the end of May 2022. ... Summary of 17 May 2022 IFA Roundtable, Q.7, under s. 233.3(1) – specified foreign property – (a). ...