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CRA concluded that the CEWS was not government funding under the definition, given that it “is a refund in respect of income taxes imposed under the ITA” and it “is not paid for the purpose of financially assisting the NPO in carrying out the purposes of the NPO. “ CRA applied a somewhat similar analysis to find that the 10% temporary wage subsidy for employers program also did not count as government funding. ...

13 July 2021- 11:02pm CRA indicates that a s. 149(1)(n) corp. must construct rather than purchase its low-rental housing projects Email this Content S. 149(1)(n) exempts the income of a limited-dividend housing company (within the meaning of … section 2 of the National Housing Act), all or substantially all of the business of which is the construction, holding or management of low-rental housing projects. ...

CRA confirmed that, regarding the narrow issue of the FMV of the common shares immediately before the death of the taxpayer, given that the insurance share was retractable by the holder immediately before the death for the CSV, it would not be unreasonable to allocate the policy CSV to the insurance shares – so that the value of the common shares would not take the policy CSV into account. ...

Summary of 16 July 2021 Internal T.I. 2020-0872521I7 under s. 125.7(1)- “qualifying rent expense” – para. ...

4 August 2021- 10:59pm CRA applies Ensite in determining whether assets are “used in the course of carrying on business” Email this Content One of the requirements for the continuity rule in s. 127.5(4.2) to apply where there has been an acquisition by an eligible entity of assets from a seller with whom the eligible entity did not deal at arm’s length is that (per s. 125.7(4.1)(b)(i)) “immediately prior to the acquisition, the fair market value of the acquired assets constituted … all or substantially all of the fair market value of the property of the seller used in the course of carrying on business.” ...

GST/HST Memorandum17-13 [17.13] Application of Section 141.02 to Financial Institutions That Are Qualifying Institutions, 23 July 2021 under s. 141.02(1) – exclusive input, direct input, s. 141.02(8) and s. 141.02(32). ...

Summary of 10 August 2021 Short Form Base Shelf Prospectus of Sprott Physical Uranium Trust under Commodity Funds – Metals Funds. ...

CRA ruled that the pref redemption would not reduce the safe income on hand attributable to the common shares – noting in its summary that this was because there was no inherent gain on such pref. ...

On a subsequent third-party sale by the trust of those shares, the QSBC definition requires that the shares have been owned by the trust, or a person related to the trust, for the prior 24-month period – and in this regard, s. 110.6(14)(c)(ii) provides that where a person who sold shares to a trust was related to all the beneficiaries, that person and the trust are deemed to have been related for the above purpose. ...

CRA stated: If the facts and circumstances of a specific case demonstrate that the financial dependence of one party on another is such that it is possible for the CRA to conclude that a transaction or series of transactions was entered into between persons not dealing with each other at arm's length under any of the criteria listed in … S1-F5-C1, [para. 1.38, respecting a common mind directing the bargaining, acting in concert or de facto control], then such dependence may be sufficient to conclude that the parties are not dealing at arm's length. ...