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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). ... (a) nor (b) of the definition- nor is it under (d)(ii) since the former part of the residential complex was previously occupied – so that s. 195.1(1) could not apply to prevent the application of the s. 206 rules. ...

If on an examination or audit, CRA determined that an NHR claim was filed in error, and an amount would become payable as a result of the NHR denial, CRA would consider the claimant’s eligibility for an NRRPR and if the claimant was determined to be eligible, the NRRPR amount would be offset against any amount owing from the NHR denial – even if the examination or audit continued beyond the relevant two year rebate filing time limit. ... The claimant may send their request in writing to the same tax centre they sent their original application …. ...

Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025-- summary under Paragraph 214(3)(a) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(3)- Paragraph 214(3)(a) Deferred imposition of Part XIII tax 1.90 … If there is no series of loans or other transactions and repayments, the non-resident who has received a loan in a particular taxation year cannot be deemed to have received a dividend until one year after the end of the lender's tax year. ... If the tax is not remitted by this day, interest will start accruing as of the 16th day of the month following the end of the lender's tax year. 1.92 If a PLOI election is available in respect of a loan but has not yet been filed, the CRA will assess Part XIII withholding tax after the time period described in subsection 15(2.6) has elapsed. … Assignment of loan before repayment 1.97 In a situation where a loan amount that is owed by a non-resident borrower has been assigned by the original lender to a new lender and the borrower subsequently repays the loan to the new lender, the borrower may still be entitled to a refund of the Part XIII tax previously assessed. ...

. … [T]he payment of a fee by the subsidiary with respect to th[e] guarantee might taint the trust. In … 2004-006822, the CRA was satisfied that the guarantee described therein would not disqualify the mutual fund trust under subparagraph 132(6)(b)(i), even though it was provided to a corporation which was not wholly owned by the trust because the particular facts indicated that the guarantee formed part of the core investment undertaking of the trust. ...

. … Exceptions to the direct use test- borrowed money used by a partnership to return capital to a partner 24. The concepts described in ¶ 23 are equally applicable where a partnership borrows money to return capital to a partner. ...

Does the first fact pattern in the Explanatory Notes under the heading "Example – Exchangeable Shares", involving a share of a Canco that is exchangeable by its terms for shares of a Forco, not constitute a "derivative forward agreement" because the exchange right embedded in the share is not an agreement? CRA responded: The DFA rules are… intended to address certain structures that have the effect of transforming income into capital gains. … The CRA cannot confirm that an exchange right embedded in a share is not an "agreement" for purposes of the DFA definition. ...

Read, "Section 55: A Review of Current Issues," 1988 Conference Report (Canadian Tax Foundation), 18:1-28-- summary under Safe-Income Determination Time Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(1)- Safe-Income Determination Time Safe income excludes income earned after the commencement of the series (p. 18:4) The period of time relevant to the calculation of “ the income earned or realized” by a corporation in relation to a particular share of that corporation will commence on the later of January 1, 1972 and the date of acquisition of that share, and will end “ before the transaction or event or the commencement of the series of transactions or events” referred to in paragraph 55(3)(a). ...

Finance responded: We agree that … the transactions described above ought not to give rise to two concurrent upstream loans, and two related income inclusions under the upstream loan rules. We are therefore prepared to recommend … rules- similar to the deemed repayment rules in subsections 15(2.18) and (2.19) (which apply for the purposes of the back-to-back shareholder loan rules in subsections 15(2.16) and (2.17), but with such modifications as are required by the context of the upstream loan rules- that would deem all or a portion of a loan that is deemed to be made under subsection 90(7) to be repaid for the purposes of paragraph 90(8)(a) and subsection 90(14) if certain conditions are met. ...

Specifically … the amount of tax payable in respect of the Services by the SLFI in that reporting period would be included in its SAM formula calculation which is used to determine the SLFI’s tax liability for the provincial part of the HST for the participating provinces and which is an adjustment to the SLFI’s net tax calculation and interim net tax calculation where applicable. ... Essentially, the SAM formula computes a normative amount of provincial HST based on the deemed residence of its stakeholders, and compares this with the actual provincial HST paid to its suppliers – and then requires that the difference be reported and claimed as refunds or remitted as tax in interim and final returns. ...

. … Listing of uncertain tax positions not privileged The taxpayer’s list of uncertain tax positions that relates to the tax reserve in their financial statements is not a privileged document. … Exclusions of advisors’ tax analysis may be accommodated Provided all the relevant facts of the transactions are disclosed, including the taxpayer's purpose or purposes in undertaking a transaction or series of transactions, exclusions of their advisors’ analysis of the legal and tax effects of the transactions may be accommodated. ...