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28 September 2020 External T.I. 2019-0800551E5- Provincial Residency of a TFSA Trust-- summary under Subsection 2601(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 2601- Subsection 2601(2) office of investment manager was PE to which securities trading income of TFSA was allocated When asked where a self-directed TFSA was resident, CRA indicated that the trust would always be resident where its central management and control was factually exercised by the trustee – irrespective of the level of involvement of the TFSA holder in the decisions. ...

Since the benefit … arises from the issuance of shares, paragraph 7(3)(b) precludes a deduction by EmployerCo in respect of that benefit. ...

In such case … the Limited Partnership’s proposed acquisition and ownership of the Furniture for the purpose of furnishing the rental units in the Residence would not be a distinct activity that is separate from its activity of leasing real property. ...

The determination of whether a Payment is included in qualifying revenue and/or excluded from qualifying revenue on the basis that it is an extraordinary item is a question of fact …. ...

Unless the Payments were considered qualifying revenue, the Contractors would qualify for the CEWS – but if they receive it, the Operator will reduce future amounts paid by a corresponding amount. ...

If the PF is an EBP, the amounts received therefrom would be taxable under s. 6(1)(g), subject to exceptions including that in s. 6(1)(g)(iii) regarding pension benefits received out of the plan that are attributable to services rendered by a person while a non-resident in Canada – as to which there would be fully taxability under s. 56(1)(a)(i) regardless of non-deductibility of contributions to the plan or a foreign tax exemption for the benefits. ...

Amounts paid to the employee for such travel must therefore be included in computing the employee's income … [and] the employee cannot deduct personal travel expenses in computing income from an office or employment. ...

Since the equitable interest of the donee arose at the moment of the creation of the trust, CRA did not construe there to be a gift of substituted property by the GRE – so that s. 118.1(5.1)(b) did not apply. ...

22 June 2020 External T.I. 2020-0848721E5 F- SSUC- Entité déterminée et institution publique-- summary under Subsection 149(1.1) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1.1) example of application of s. 149(1.1) In the course of a general response to a query by a non-profit organization regarding the exclusion from an "eligible entity" for CEWS purposes of a “public institution” as defined in s, 125.7 (including an organization described in any of ss. 149(1)(a) to (d.6),) CRA stated: [S[subsection 149(1.1) … provides that for the purposes of determining the 100% and 90% ownership tests in paragraphs 149(1)(d) to (d.6) of the Act any right to acquire shares or capital of a corporation should be considered as though the right had been exercised. ...

Consequently, the client would not qualify for the wage subsidy in respect of the payment made to the staffing company … [Y]ou mentioned that the client has received an offsetting discount for the wage subsidy received by the outsource staffing company. ...