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As confirmed in Question 9 on the Canada.ca webpage, Frequently asked questions – Canada emergency wage subsidy (CEWS) (footnote 1), if a group of eligible entities generally prepares consolidated financial statements, each member of the group will determine its qualifying revenue for purposes of the CEWS in accordance with those consolidated statements. ...

You referenced our guidance in paragraph 7 of Interpretation Bulletin IT-91R4 – “Employment at Special Work Sites or Remote Work Locations” (“IT-91R4”) about how a “room (or rooms) in a hotel, dormitory, boarding house or bunkhouse would not ordinarily be a self-contained domestic establishment”, which you consider pertinent to the issue raised in your inquiry. ...

14 July 1989 External T.I. 73900 F- Overseas Employment Tax Credit and Northern Residents Deduction Unedited CRA Tags 110.7(1), 110.7(2), 122.3(1)   July 14, 1989 K. ...

16 December 1991 External T.I. 9107435 F- Short Sale of Stocks Unedited CRA Tags 9, 260   910743 Dear Sirs: Re:  Short Sale of Stocks We are writing in response to your correspondence of March 12, 1991 regarding the treatment for income tax purposes of a short sale of stocks by a brokerage firm. ...

Advance Corporations Tax Unedited CRA Tags ITR 5907(1)(f), 5907(1)(d)(vi.1), 5907(1.2), 5907(7.1)   FOREIGN AFFILIATES- U.K. ...

9 December 1991 External T.I. 9124715- Allocation de retraite Unedited CRA Tags 60(j.1), 248(1) allocation de retraite   5-912471 Messieurs, Mesdames, OBJET:  Allocation de retraite Paragraphe 248 (1) et alinéa 60 (j.1) de la Loi de  l'impôt sur le revenu (la "Loi")            La présente fait suite à vos lettres en date du 9 septembre et du 14 novembre 1991 concernant le sujet ci-haut mentionné.  ...

Position: Generally, 90 % or more of the FMV. However, other measuring sticks may be used depending on the circumstances. ...

If the method used in the Particular Situation was not “fair and reasonable” – would that make the PAC non-operating for purposes of the Act, and therefore prohibit the CRA from adjusting the redemption value of the preferred shares? ... Yours truly, Maurice Bisson, CGA Section Manager Corporate Reorganization Section IV Reorganizations Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 IT-169 – Price Adjustment Clauses, August 6, 1974 (hereinafter “IT-169”), at par. 1. 2 Gurberg v. ...

Subparagraph 40(1)(a)(i) of the Act states: "Except as otherwise expressly provided in this Part (a) a taxpayer's gain for a taxation year from the disposition of any property is the amount, if any, by which (i) if the property was disposed of in the year, the amount, if any, by which the taxpayer's proceeds of disposition exceed the total of the adjusted cost base to the taxpayer of the property immediately before the disposition and any outlays and expenses to the extent that they were made or incurred by the taxpayer for the purpose of making the disposition, …" Question 1 In regard to "Question 1", the PSA specifies that the shareholder will receive, on the closing date, proceeds of disposition of $5,000. ... Therefore, since A – B is equal to zero there is no "forgiven amount" and as a result the forgiveness of debt rules in section 80 of the Act would not apply to Aco. ...

It is also our view that, if a pre-March 28, 2012, debt is replaced with a newer debt of the same or substantially similar amount, the transactions may constitute a series of loans or other transactions as discussed in ¶ 28 of IT-119R4, Debts of Shareholders and Certain Persons Connected With Shareholders. However, as discussed in ¶ 29 of IT-119R4, in any given situation, all of the relevant factors would need to be considered to determine whether a series of loans or other transactions and repayments existed and bona fide repayments would not be seen as part of a series of loans or other transactions and repayments. ...