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CRA indicates that an entity may be an eligible entity for CEWS purposes if it is not a public institution

Summary of 23 June 2020 External T.I. 2020-0848441E5 F under s. 149(1)(c) and s. 125.7(1) – eligible entity. ...

CRA rules on split-up butterfly that avoids Pt IV tax circularity by a subsequent wind-up of the distributing corporation

Summary of 2020 Ruling 2018-0772291R3 F under s. 55(1) – distribution. ...

It is queried whether Canadian taxpayers are owners of securities held by them through intermediaries in accordance with the Securities Transfer Acts

Tax Topics (Wolters Kluwer), No. 2556, 2 March 2021, p. 1 under General Concepts – Ownership. ...

CRA indicates that where there has been a s. 125.7(4.1)(e) election, the asset purchaser picks up all rather than part of the seller’s qualifying revenues for the prior reference period

Instead, “the assigned revenue described in paragraph 125.7(4.2)(a) … refers to the qualifying revenue of the seller for the entire prior reference period that is reasonably attributable to the acquired assets.” ...

CRA will not follow the ARQ in allowing a s. 164(6) loss carryback claim on a terminal return before the GRE’s T3 return is assessed

Relaxing CRA's procedures and any administrative policy in that regard would require a thorough review …. ...

CRA states that an eligible dividend designation must state a dollar amount, and that GRIP variances are addressable under s. 185.1(2)

CRA also noted that, administratively, it: [a]llows … mitigating the effects of an excessive eligible dividend designation by accepting that the election provided for in subsection 185.1(2) can be made by a corporation at the time of filing its income tax return, without having to wait for a notice of assessment of Part III.1 tax to be issued. ...

CRA indicates that whether receipts are gross REIT revenue is informed by their accounting treatment

Summary of 22 February 2021 External T.I. 2018-0784661E5 under s. 122.1(1) – gross REIT revenue. ...

CRA indicates that a s. 17(8) exception for a loan by a partnership of two related Cancos to an FA does not imply a s. 247(7) exclusion of s. 247(2)

CRA stated that it was “not prepared to take an administrative position to consider that subsection 247(7) would apply in respect of the loan between the FA and LP ….” ...

CRA would include the full FMV of a RRIF in the annuitant’s income on death given no payment thereunder to the spousal beneficiary before that survivor’s death

Summaries of 12 March 2021 External T.I. 2020-0867001E5 under s. 146.3(1) – designated benefit and s. 146.3(3.1). ...

CRA implies that hair stylists’ chair rents might qualify as rent for CERS purposes

Summary of 11 May 2021 Internal T.I. 2020-0869981I7 under s. 125.7(1) – qualifying rent expense. ...

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CRA indicates that an entity may be an eligible entity for CEWS purposes if it is not a public institution

CRA rules on split-up butterfly that avoids Pt IV tax circularity by a subsequent wind-up of the distributing corporation

It is queried whether Canadian taxpayers are owners of securities held by them through intermediaries in accordance with the Securities Transfer Acts

CRA indicates that where there has been a s. 125.7(4.1)(e) election, the asset purchaser picks up all rather than part of the seller’s qualifying revenues for the prior reference period

CRA will not follow the ARQ in allowing a s. 164(6) loss carryback claim on a terminal return before the GRE’s T3 return is assessed

CRA states that an eligible dividend designation must state a dollar amount, and that GRIP variances are addressable under s. 185.1(2)

CRA indicates that whether receipts are gross REIT revenue is informed by their accounting treatment

CRA indicates that a s. 17(8) exception for a loan by a partnership of two related Cancos to an FA does not imply a s. 247(7) exclusion of s. 247(2)

CRA would include the full FMV of a RRIF in the annuitant’s income on death given no payment thereunder to the spousal beneficiary before that survivor’s death

CRA implies that hair stylists’ chair rents might qualify as rent for CERS purposes

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