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Summaries of 16 January 2023 Internal T.I. 2020-0851561I7 F under s. 125.7(1) – eligible remuneration, and baseline remuneration. ...

In granting leave, the Supreme Court indicated that this appeal will be heard with Dow Chemical ULC – presumably, on the basis that both deal with the demarcation of the respective jurisdictions of the Federal Court and Tax Court. ...

Thus, the issue would turn on whether there was substantial renovation of the physical space for each proposed condo unit – with CRA reiterating in this regard its longstanding position that to rise to the level of substantial renovation there would need to be a gutting (or more) of each unit at issue. ...

In finding that s. 190(1) would not apply, CRA noted that the s. 190(1) preamble requires that a person begins to hold or use real property as a residential complex – whereas here, the person (NewCo) held a single residential complex both before and after the transaction (merely expanding the size of its residential complex). ...

Summary of GST/HST Memorandum 18-4 “Determining Whether a Transfer Payment is Consideration For a Supply” June 2022 under ETA s. 123(1) – consideration. ...

It stated: [T]he Notice of Intent … is a compliance tool to be used at the disposal of the CRA; it is not taxpayer-initiated. ...

Accordingly, there was no question of whether or not to introduce an economic substance component – rather, it was a question of how to do so while not at the same time upending the GAAR rule and throwing out 30 years of caselaw. ...

Summary of 7 April 2022 CBA Roundtable, Q.15 under ETA s. 217 – imported taxable supply. ...

After noting that the benefit from rent-free use of the property would generate Part XIII tax under ss. 15(1), 15(1.4)(c) and 214(3)(a), CRA indicated that, where the fair market rent did not provide a reasonable return on the value of the property, the amount of the benefit was to be determined using the imputed rent approach – which in general entailed multiplying a normal rate of return for the non-resident corporation by the greater of the cost and fair market value of the property, and adding operating costs other than interest paid on liabilities connected with the property. ...

Summary of 2021 Ruling 2020-0865991R3 under s. 212(3) – participating debt interest. ...