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Therefore, the 87(1)(a) condition would be met – all property of the predecessor corporation becomes property of the new corporation by virtue of the amalgamation. ...

CRA indicated that having claimed the s. 20(1)(ww) deduction would not preclude X from subsequently claiming the s. 20(1)(j) deduction when the loan was repaid – and indicated that this appeared to be the right policy result. ...

CRA indicated that, pursuant to Reg. 100(4)(a)- which deems an employee, who is not required to report for work at any establishment of the employer, to report for work at the establishment from which the employee’s salary and wages are paid – Mr. ...

17 May 2022 IFA Roundtable Q. 13, 2022-0926381C6- Statistics on MAPs-- summary under Article 26 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 26 around half of CRA’s recent MAP cases resulted in full relief CRA provided the following statistics on MAPs for the 2020 calendar year: … The average time to complete a negotiable MAP case was 17.83 months; Of the 74 MAP cases closed in 2020, 36 cases (i.e., 48.6%) resulted in full relief from double taxation upon negotiation, 9 cases (i.e., 12.2%) had objections not justified, and 8 cases (i.e., 10.8%) were resolved through unilateral relief. ...

., and stated: [T]here are arguments to support the contention that the building used 65% by ABC Inc. in its manufacturing activities could be a property used or held primarily to earn income from its manufacturing business for the purposes of subparagraph (b)(ii) …. ...

. … [C]rypto-assets, by their very nature, are more difficult to track than traditional assets. ...

(e) of the “flow-through critical mineral mining expenditure” definition that the required certification by a “qualified engineer or geoscientist” be “completed … no more than 12 months before the time that the agreement is made,” CRA indicated that the prescribed form is in the process of being completed and will be released to the public very shortly, and that it should be attached to one of the existing forms that are already required in connection with a flow-through share offering, such as the T100A. ...

However, the registered charity would be an “exempt person,” which is defined in s. 94(1) to include a person exempted under s. 149(1), and thus would be excluded from being a “resident beneficiary” (under the preamble of that term’s definition) – so that s. 94 would not apply to the trust. ...

CRA stated: The CRA’s view remains that subsection 15(1) … applies when a non-resident corporation confers a benefit in the form of making available to its non-resident shareholder or to an individual that does not deal at arm’s length with the non-resident shareholder (such as their family members) a property located in Canada. ...

In the case of the gift, CRA noted that although s. 69(1)(c) would deem the building’s cost to the resident to be its FMV of $1.4 million, the ½ step-up rule in s. 13(7)(e)(ii) would reduce the capital cost of the building to the resident to $1.2 million, so that the starting undepreciated capital cost of the building would also be that amount. ...