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IV tax under s. 186(1)(b) in the hands of Holdco – so that the exclusion in the preamble to s. 55(2) applies to the extent that such Pt. ...

Summary of 2021 APFF Financial Strategies and Instruments Roundtable, Q.3 under s. 54 – superficial loss. ...

Summary of Tu Vu, “Application of Disproportionate UFT Election,” Canadian Tax Focus, Vol. 11, No. 4, November 2021, p. 15 under Reg. 5907(1)- underlying foreign tax applicable – para. ...

Summary of APFF Financial Strategies and Instruments Roundtable, Q.9 under s. 204.2(1.2)- undeducted RRSP premiums – J. ...

In particular having regard to the CRA view that “to be a right or thing [under s. 70(2)] … the individual would have to be legally entitled to receive the amount at the time of the individual’s death (the right would have to exist)” CRA considered that even though an individual annuitant who died part way through the year was allocated the income that had been earned in the year up to the time of death on the T3 slip received by his executors, he had no legal entitlement to the allocated amounts. ...

(e) of the specified shareholder definition to wholly-own Holdco, so that each child also would be a specified shareholder, under that definition, of the related corporation (Subco) – thus the test in s. 74.4(2)(a) also would be satisfied. ...

A) and the two children – following which the shares of Mr. A and of the children would be transferred on a s. 85(1) rollover basis into a holding company controlled by Mr. ...

15 December 2021- 11:27pm CRA now indicates that it will only provide transitional administrative relief regarding the GST/HST “digital economy” measures where there is voluntary disclosure Email this Content Although CRA misleadingly refers to the 2021 Budget as having introduced, effective July 1, 2021, “GST/HST measures that related to the digital economy,” those measures are broader than that – essentially any non-resident making most types of supplies of services (other than financial services) or intangible personal property to Canadian recipients who are not registered must itself register for GST/HST purposes once it exceeds a de minimis threshold. ...

CRA provided the following list of expenses which are generally not incurred as agent for the client: office supplies, if they are associated with the service being performed by the supplier for the client air travel local transportation, such as a taxi parking hotel or other accommodation per diem amounts, such as meals car rentals and gasoline an automobile allowance, where the supplier’s personal vehicle is used in the performance of the service Before discussing the 50% denial of ITCs for food, beverage and entertainment expenses, CRA indicated: Generally, a client who is a registrant can claim an ITC for the GST/HST paid or payable on the out-of-pocket expenses incurred by a supplier as agent of the client … to the extent that the supplier’s services and the supply acquired by the supplier are consumed, used or supplied in the course of the client’s commercial activities. ...

., half and half, or $7.50 and $7.50) – so that the provincial FTC for each country would be $2.50 (being the Ontario domestic factor of 1, multiplied by the excess of $10 of the NBIT paid to each country over $7.50). ...