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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. ...

GST/HST Notice No. 324, "Mining Assets in respect of Cryptoassets" June 2025-- summary under Subsection 200(2) Summary Under Tax Topics- Excise Tax Act- Section 200- Subsection 200(2) Application of change-in-use rules as a result of virtual payment instruments becoming financial instruments on May 18, 2019 under " ITCs where virtual payment instruments are payable in respect of mining activities" Any capital property that the person held as of May 18, 2019, is subject to the change-in-use provisions in the ETA where supplies made after May 17, 2019, of the virtual payment instruments, acquired as a result of this mining activity, were not supplies made in the course of the person’s commercial activities. ...

. … 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. ...