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CRA Webpage, "Notifiable transactions designated by the Minister of National Revenue," 15 August 2024-- summary under Subsection 237.4(3) Summary Under Tax Topics- Income Tax Act- Section 237.4- Subsection 237.4(3) Straddle transactions of FX-trading partnership (NT-2023-01) A taxpayer buys an interest in a partnership which, immediately prior thereto, had realized the gain legs on straddle transactions in FX forward contracts (with such gain allocated to the selling partner) – and with the loss legs then being realized and allocated to the taxpayer. ...

. … Computation where depreciable property converted to inventory 18. ...

. … The amount in the reinsurance premium described above as the margin for risk transfer is not considered to be included in loading as defined in section 217. ...

GST/HST Memorandum 19.5 "Land and Associated Real Property" October 2001-- summary under Business Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Business Appendix C … General distinction between a regular business and an adventure General approach 3. ...

Mutual fund dealers whose clients invest with other FIs 6.2 … Subsection 263(3) of the ITA makes clear that a financial account includes a client-name account maintained by a person or entity that is authorized under provincial law to engage in the business of dealing in securities or any other financial instrument or to provide portfolio management or investment advising services. ...

. … Example 1: inclusion of signing bonus subject to repayment As an inducement to a prospective employee to accept an employment offer, an employer agrees to make a payment when the individual signs the employment contract. ...

. … 16. If a VDP application is accepted into the Limited Program, no interest relief will be provided. ...

. … 68. The following are some of the factors that generally indicate that a given supply is a supply of a service of instruction: The activity involves the provision of systematic instruction. ...

Required homogeneity of cost pools Appropriate costs pools … If direct inputs are grouped together for ITC allocation purposes, all the direct inputs within the cost pool must: be for use to the same extent for the purpose of making taxable supplies for consideration if the inputs in the pool are tracked (e.g., a pool of inputs that are tracked cannot include an input that is used 2% for the purpose of making taxable supplies for consideration with an input that is used 30% for the purpose of making taxable supplies for consideration); be allocated using the same, appropriate, allocation base if the inputs in the pool are allocated using causal allocation; apply to the same portion of the business if the input is allocated using input-based allocation; and apply to the same portion of the business and use the same appropriate output measures (e.g., revenue) if the input is allocated using output-based allocation. ...

VII: extended relief for Canadian residents exercising their U.S. employment at home in Canada for COVID reasons (with Treaty-reporting alternative) Where as a result of the travel restrictions, Canadian-resident individuals have been forced to perform their duties for a U.S. employer from their Canadian home and (for the initial relief period) their employer received a CRA letter of authority (to reduce the Canadian source deductions at source to reflect the available foreign tax credit), as an administrative concession, CRA will treat the employment income from the U.S. employer for 2020 that was subject to U.S. withholding as having a U.S. source – so that those individuals can file their tax returns as in prior years and claim a foreign tax credit for the U.S. taxes. ...