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After noting that “where a loss from a subsequent taxation year is carried back to a particular taxation year, the revised income taxes payable and any resulting refund are computed using the exchange rates applicable to that particular year, regardless of the exchange rate in the subsequent year,” CRA indicated that this situation was essentially dealt with in Folio S5-F2-C1, which addresses the reverse situation of FX gains in Canadian dollars on foreign tax refunds or payments – so that, here, the FX gain was a capital gain to be computed based on the FX rate change between that appliable to the previous year and that at the time of receipt. ...

Summary of Michael Kandev and John Lennard, "The OECD Multilateral Instrument: A Canadian Perspective on the Principal Purpose Test", Bulletin for International Taxation, January 2020, p. 54 under Treaties- MLI – Art. 7(1). ...

The report found that it was abusive and improper for the ARQ to reassess without an adequate evidentiary foundation capable of surviving judicial scrutiny – and that, in such instances, the reassessment should be dropped. ...

Summary of May 2019 CPA Alberta CRA Roundtable, GST Session – Q.3 under ETA s. 211(5)(c). ...

Summaries of May 2019 CPA Alberta CRA Roundtable, GST Session – Q.8 under ETA s. 133 and s. 169(1). ...

Summary of 27 January 2020 External T.I. 2019-0799641E5 under s. 118.1(1)- “total gifts”- (a)(iii) – B. ...

Summary of Frequently Asked Questions – Temporary Wage Subsidy for Employers 20 March 2020 CRA Webpage under s. 227(4). ...

1 April 2020- 11:29pm CRA announces that there will be no penalties for late-filing GST/HST returns on June 30, 2020 Email this Content CRA has announced that although “The deadline for businesses to file their [GST/HST] returns is unchanged … the CRA won’t impose penalties where a return is filed late provided that it is filed by June 30th.” ...

In the case of a short sale transaction, the cost of the shares sold short is the fair market value of the shares at the time they are borrowed for the purpose of being sold short – so that the cost of the sales sold short is not the cost of the shares subsequently purchased to cover the short. ...

Summary of 2019 Ruling 2019-0817751R3 under s. 248(1) – salary deferral arrangement. ...