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. … [U]nless the Dependent Beneficiary is the person legally entitled to the surplus income a trust will not qualify as an LBT as there is the possibility that a person other than the Dependent Beneficiary can receive or obtain, during the Dependent Beneficiary’s lifetime, the use of the income of the trust. ...

Thus, it is our view that the amount will not be included in the borrower’s income …. ...

CRA indicated that it had the discretion to grant a request to reduce the carrybacks so as to eliminate the GRIP reduction and associated Part III.1 tax (so that it might grant such request if it was satisfied that this was “a situation involving a bona fide error and not amounting to retroactive tax planning) provided that the loss years (2019 or 2020) were not statute-barred and that the request to reduce the carryback satisfied “the conditions … in subparagraphs 152(4)(b)(i) and 152(4.01)(b)(i) in respect of the [prior] Years.” ...

13 April 2023 External T.I. 2017-0684341E5 F- Perte au titre d’un placement d’entreprise-- summary under Paragraph 39(1)(c) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(c) active business for SBC purposes can continue after regular business operations have ceased/ sale of debt for $1 to unrelated purchasers might be a non-arm’s length transaction An individual was the sole shareholder, and held an interest-bearing debt (the "Debt" – acquired for an income-producing purpose), of a corporation operating a restaurant which in 20X1 sued the franchisor at the same time as closing the restaurant. ...

. … Even if a grant of full-value RSUs was related to past services, it is also still possible that those past services were rendered solely in the Grant Year. ...

After noting that “on July 22, 2022, the Minister of Crown-Indigenous Relations announced that the section 87 tax exemption would be available for continuation on modern treaty governments’ former reserves and other First Nations reserves in Canada for prospective and existing modern treaty government beneficiaries who are registered or entitled to be registered under the Indian Act ”, CRA stated: [W]e agree with updating the Guidelines to allow modern treaty governments or organizations controlled by modern treaty governments to be eligible employers under Guideline 4. ...

Although the ordinarily-inhabited condition under the principal residence definition would not generally be met for the Secondary Suite while being rented to third parties, where it was subject to the s. 45(2) election it could nonetheless qualify as the taxpayer’s principal residence for up to four taxation years during which the election remained in effect – so that the homeowner would be able to choose for such a year to designate the Secondary Suite rather than the balance of the property as that taxpayer’s principal residence. ...

., the actual capital cost grossed-up to $15,000,000 and multiplied by the 50% Class 43.2 rate); It claims the Nova Scotia Capital Investment Tax Credit (“NS CITC”) of 25% of the $10,000,000 capital cost, or $2,500,000 and receives it by way of credit or refund; It claims and receives the Clean Technology Investment Tax Credit (“Clean Tech ITC”) pursuant to s. 127.45, which is calculated as 30% of the capital cost, as reduced by the NS CITC, viewed as government assistance that it can “reasonably be expected to receive” (on December 31, 2024, receipt of the NS CITC is contingent on it receiving, by its filing-due date, an entitlement certificate); It claims an Atlantic Investment Tax Credit (“AITC”) pursuant to s. 127(9) of $750,000, being 10% of the capital cost, again reduced to $7,500,000 by the NS CITC “government assistance” – and receives the AITC by way of credit against federal tax payable in the current year or during the carryforward or carryback period. ...

The two deferred payments were not made on the agreed dates because of disagreements about the method for their computation. 21 months after the closing date, the parties agreed that a deferred payment of $50,000, rather than $200,000 + $300,000, would be paid. ...

Further … a personal guarantee of the amount owing under a vendor take-back promissory note by the controlling shareholder of the purchaser corporation would not, where the purchaser corporation has the capacity to make the scheduled payments under the promissory note (and absent any other factors indicative of de facto control), result in the holder having de facto control of the purchaser corporation. ...