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Summary of 8 August 2019 Internal T.I. 2018-0776661I7 under s. 9 – computation of profit. ...

. … [I]t is likely that the employer is the primary beneficiary of an employee’s travel to and from home in between the first and last call out of a standby shift. ...

10 October 2019- 12:44am CRA applies its view that a partner is attributed each PE of a partnership for Reg. 400/403 purposes Email this Content Under Regs. 403(1) and (3), a property insurer (or, in this case, a reinsurer) is required to allocate its taxable income to the provinces on the basis of the respective proportions of its net property insurance premiums that are arrived at by allocating its net premiums to the provinces where the insured property is situate – except that if it does not have a permanent establishment in a particular province, the net premiums for the insured property in that province are allocated to the province which has a PE to which those net premiums are “reasonably attributable.” ...

. … [T]he safe income attributable to the shares of the capital stock of Holdco should be $900,000, which is the safe income attributable to the shares of the capital stock of Opco 1 held by Holdco. ...

In response to a suggestion that it was CRA policy that “if a public service body has been charging GST/HST on supplies of real property that would otherwise be exempt, and has been accounting for that tax and claiming input tax credits (ITCs) in its net tax calculations and remittances as if the s. 211 election had been filed on time, then the CRA will normally accept a late-filed section 211 election,” CRA stated: [A] decision on whether to accept a backdated effective date for a section 211 election falls within the purview of the Domestic Compliance Programs Branch … [which] will only consider the backdating of a section 211 election in exceptional circumstances. ...

CRA also indicated, in the situation where the death had occurred before the deceased could withdraw the minimum amount for the year of death, but the transfer of his RRIF to the surviving spouse was not made until the following calendar year, then there was no need for the RRIF issuer to pay the minimum amount for the year of death – but that the eligible amount received by the surviving spouse in the subsequent year would be reduced by the minimum amount for that year. ...

V, s. 7(f) applies to “a service of … soliciting orders for supplies by or to the [non-resident recipient, i.e., NR]” whereas here the solicitation was for supplies by the Canadian customer of NR.) ...

CRA also reiterated its position that s. 296(2.1) only applies where a registrant has failed to claim (rather than claimed) a rebate – so that, for example, s. 296(2.1) could apply to require CRA to grant the NRRPR where it has assessed a developer for failure to self-assess. ...

Summary of 10 May 2019 GST/HST Ruling 167225 under ETA s. 123(1) – debt security. ...

CRA also noted: … Municipalities in participating provinces may be entitled to a PSB rebate of 100% of the federal part of the HST but only entitled to a lesser percentage of the provincial part of the HST. ...