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

Summary of 6 May 2019 GST/HST Interpretation 194986 under ETA s.123(1) – financial service – (r.4). ...

Summaries of 3 June 2020 External T.I. 2020-0846831E5 under s. 125.7(1) – eligible entity – (c), and s. 149(1)(c). ...

. … [It]s review … may take some time. Therefore, any change of position would likely be disclosed at a future CRA Round Table, rather than in the context of a technical interpretation. ...

2 September 2020- 10:59pm CRA will no longer issue SDA rulings on formula-based incentive plans for employees Email this Content CRA got cold feet about ruling that formula-based incentive plans are not salary deferral arrangements after considering, and rejecting, a proposed plan under whose units’ value on their redemption date would be based on changes in EmployerCo’s retained earnings between the grant and redemption date plus dividends paid over the same period – so that the units’ value would have increased over the duration of the vesting period even if EmployerCo’s net earnings remained stable over the period (as had been the case in prior years). The Directorate explained that it has now developed a concern “that the financial metrics that underlie formula-based appreciation plans may be susceptible to manipulation … [which] can be used to obfuscate the fact that a formula-based appreciation plan’s underlying purpose is to defer tax,” and in that regard has announced: that it: will no longer consider any ruling requests pertaining to whether any given formula-based appreciation plan is a SDA, unless: i) the plan is of a type described in ATR-45 …; or ii) the ruling request pertains to whether one of the enumerated exceptions listed in the definition of SDA apply to the plan. … [S]hare appreciation rights (“SAR”) plans … described in ATR-45 … [have] the following characteristics: The unit has no intrinsic value at the date of grant; The value of a unit is not guaranteed and may have a negative value after the date of grant; and The value of each unit at any particular time is determined by subtracting the FMV of a share of the employer at the date of grant from the FMV of a share of the employer at that particular time. … [O]ur decision to no longer consider ruling requests for formula-based appreciation plans does not mean that the CRA now considers all such plans to be SDAs. ... Summary of 10 July 2020 Internal T.I. 2020-0850281I7 under s. 248(1) – SDA. ...

30 March 2020- 12:43am CRA confirms that accelerated CDE deductions can be available for drilling on land acquired from an affiliate Email this Content S. 66.2(2) provides an increased deduction for Canadian development expense incurred after November 20, 2018 – but with an exclusion for “a cost in respect of a Canadian resource property acquired by the taxpayer … from a person or partnership with which the taxpayer does not deal at arm’s length.” ... Summary of 6 June 2019 CPTS Roundtable, 2019-0816111C6, Q.6 under s. 66.2(5) – accelerated CDE – (a)(ii). ...

Summaries of 24 January 2020 GST/HST Ruling 194625 under ETA s. 123(1) – financial service – para. (l) and Financial Services and Financial Institutions (GST/HST) Regulations, s. 4(1) – person at risk. ...

Summaries of Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)," Bulletin for International Taxation, November 2017, p. 607 under Treaties – MLI – Art. 20, Art. 19 and Art. 28(2). ...

In computing Part XII.6 tax of the PBC for February to June 2020, it is deemed to have incurred $3M of CEE before the end of those months, so that the tax would be computing (applying the prescribed rate of 2%) in accordance with the formula: ($5M- $3M) X (0.02/12 + 0/10) = $3, 333 so that the tax for each month during that period is $3,333. ...

Topic Descriptor 15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F- IFA 2020 Roundtable – T2057 & Functional Currency Income Tax Act- Section 261- Subsection 261(5)- Paragraph 261(5)(a) different currency reporting of s. 85(1) rollover where one party has elected a funcitional currency Income Tax Act- Section 85- Subsection 85(1) dual-currency filing of s. 85 elections where the transferor and transferee have different tax reporting currencies 15 September 2020 IFA Roundtable Q. 2, 2020-0852741C6- IFA 2020- Q2- WHT on mismatched swap payments Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(b) interest not imputed on mismatched cross-border swap payments 15 September 2020 IFA Roundtable Q. 3, 2020-0853371C6- IFA 2020 Q3: Draft IC71-17R6, Paragraph 43 Treaties- Income Tax Conventions- Article 26 Canada does not negotiate away its application of domestic anti-avoidance rules Income Tax Act- Section 247- New- Subsection 247(2)- Paragraph 247(2)(b) ss. 247(2)(b) and 245(2) treated the same for MAP procedure purposes 15 September 2020 IFA Roundtable Q. 4, 2020-0853391C6- IFA 2020 Q4: Impact Covid-19 on CRA procedures Income Tax Act- Section 152- Subsection 152(4) no extension under Bill-20 (re COVID) beyond December 31, 2020 Treaties- Income Tax Conventions- Article 26 COVID-19 has not changed Treaty time limitations 15 September 2020 IFA Roundtable Q. 5, 2020-0853401C6- IFA 2020 Q5: TPM-17 and COVID-19 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 Treaties- Income Tax Conventions- Article 9 Cdn governmental COVID assistance generally does not reduce cost ...