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26 November 2020- 10:57am CRA finds that the purchase and rental of furniture in a furnished apartment is assimilated to the apartment rental activity Email this Content S. 149(1)(o.2)(ii)(A)(II) permits a s. 149(1)(o.2) (pension-group) corporation to invest its funds in “a partnership that limits its activities to acquiring, holding, maintaining, improving, leasing or managing capital property that is real property or an interest in real property … owned by the partnership”. ...

., the deemed $80,000 proceeds of disposition of the capital interest under s. 107(2)(c), being the excess of the $100,000 cost amount of the distributed property, being their deemed cost to the beneficiary, over the $20,000 eligible offset amount) – whereas, for capital loss purposes, the ACB of the capital loss was determined as nil on ordinary principles, so that there also was no loss. ...

Summary of 26 November 2020 STEP Roundtable, Q.9 under s. 120.4(1) – excluded business. ...

CRA ruled that “[t]he negative repo spread … will not be considered to be interest or an amount paid or credited as, on account or in lieu of, or in satisfaction of interest for the purposes of paragraph 212(1)(b).” ...

Summary of 26 November 2020 STEP Roundtable, Q.10 under s. 120.4(1) – split income. ...

A taxpayer not qualifying for the 25% forgiveness who settles the loan for 100% of the principal may generally claim a deduction under s. 20(1)(hh) equalling the previous s. 12(1)(x) inclusion – even where the taxpayer made the s. 12(2.2) election. ...

Regarding the mechanics of the loss shift, the interest on the loan by Lossco to ACo, as well as the dividends on the corresponding preferred shares held by Aco in a Newco subsidiary of Lossco, are allowed to accumulate until the time of unwinding the structure, at which point Lossco makes a cash capital contribution to Newco to fund the payment of such dividend arrears whose payment, in turn, funds the payment of the interest owing by Aco – but the loss shifting transactions otherwise are unwound on a cashless basis. ...

Summary of 21 August 2020 Internal T.I. 2019-0834911I7 under s. 110.2(1) – qualifying amount. ...

30 December 2020- 11:37pm CRA finds that sponsorship of a PSB’s staged production was not subject to GST/HST Email this Content ETA s. 135 deem a supply by a public sector body (PSB) of a service, or a licence of copyright, a trade-mark, trade-name or other similar property to a “sponsor” for exclusive use by the sponsor in publicizing the sponsor’s business, to not be a supply – except that this rule is stated not to apply where the consideration for this supply by the PSB to the sponsor is “primarily” for radio, TV, newspaper, or magazine advertising. ...

If the PF is an EBP, the amounts received therefrom would be taxable under s. 6(1)(g), subject to exceptions including that in s. 6(1)(g)(iii) regarding pension benefits received out of the plan that are attributable to services rendered by a person while a non-resident in Canada – as to which there would be full taxability under s. 56(1)(a)(i) regardless of non-deductibility of contributions to the plan or a foreign tax exemption for the pension benefits. ...