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CRA indicated that it had the discretion to grant a request to reduce the carrybacks so as to eliminate the GRIP reduction and associated Part III.1 tax (so that it might grant such request if it was satisfied that this was “a situation involving a bona fide error and not amounting to retroactive tax planning) provided that the loss years (2019 or 2020) were not statute-barred and that the request to reduce the carryback satisfied “the conditions … in subparagraphs 152(4)(b)(i) and 152(4.01)(b)(i) in respect of the [prior] Years.” ... Summaries of 17 November 2022 External T.I. 2021-0919001E5 F under s. 89 – GRIP – B, s. 152(4)(b)(i), s. 152(6)(c), s. 152(3) and s. 185.1(2), ...

Summary of Tax on split income – Excluded shares (CRA webpage), 10 July 2019 under s. 120.4(1) – excluded shares – (a)(i). ...

Summaries of Emmanuel Sala, "Flow-Through Share Financing: Recent Developments, Traps and Tips," 2015 CTF Annual Conference draft paper under s. 66.1(6) – Canadian exploration expense – (f), s. 66(12.6)(a), s. 66(15) – flow-through share. ...

Summaries of Underused Housing Tax Notice UHTN16 Proposed Amendments to the Underused Housing Tax, 8 March 2024 under UHTA, s. 2, excluded owner – (a)(i), (b). (c)(iii), specified Canadian partnership – (a), specified Canadian trust – (a), s. 4.1, and Underused Housing Tax Regulations – s. 2(3). ...

Summary of 9 February 2017 External T.I. 2016-0657531E5 under s. 210 – designated beneficiary – para. ...

Summary of 21 December 2016 Ruling 157873 under ETA, s. 123(1) – financial service – (d). ...

Summary of 6 July 2018 External T.I. 2018-0759521E5 under s. 120.4(1) – split income – para. ...

Summary of 5 October 2018 APFF Roundtable, Q.10 under s. 120.4(1) – related business – s. ...

Summary of 2018 APFF Financial Strategies and Instruments Roundtable, Q.11 under s. 54 – principal residence – (c). ...

Summary of 9 August 2019 External T.I. 2019-0813021E5 under s. 120.4(1) – excluded share – para. ...