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Technical Interpretation - External summary
4 March 2025 External T.I. 2025-1053731E5 - DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement -- summary under Subsection 87(8.4)
4 March 2025 External T.I. 2025-1053731E5- DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement-- summary under Subsection 87(8.4) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(8.4) the Explanatory Notes on s. 87(8.4) partially conflated it with s. 87(8) The Explanatory Notes to ss. 87(8.4) and (8.5) provide: New subsections 87(8.4) and (8.5) allow taxpayers to elect for dispositions of taxable Canadian property (“TCP”) that is shares of a corporation or an interest in a partnership or trust to occur on a tax-deferred (“rollover”) basis, where the disposition results from a foreign merger that meets certain conditions. ...
Current CRA website
T4032-MB-July Payroll Deductions Tables – CPP, EI, and income tax deductions – Manitoba – Effective July 2025
T4032-MB-July Payroll Deductions Tables – CPP, EI, and income tax deductions – Manitoba – Effective July 2025 Notice to the reader Publication T4032, Payroll Deductions Tables, is available in sections for each province and territory. ... Please note that you can also use the Payroll Deductions Online Calculator (PDOC) to quickly calculate federal and provincial payroll deductions Section A t4032mb-july-general-information.html [HTML] t4032-mb-7-25e.pdf [PDF] Section B(i)- Canada Pension Plan contributions tables 52 pay periods a year (Weekly) [PDF] 26 pay periods a year (Biweekly) [PDF] 24 pay periods a year (Semi-monthly) [PDF] 12 pay periods a year (Monthly) [PDF] Section B(ii) – Second additional CPP contributions table When the province or territory of employment is other than the province of Quebec [PDF] Section C- Employment Insurance premiums tables When the province or territory of employment is other than the province of Quebec [PDF] Sections D and E- Federal and Manitoba provincial tax deductions tables 52 pay periods a year (Weekly) [PDF] 26 pay periods a year (Biweekly) [PDF] 24 pay periods a year (Semi-monthly) [PDF] 12 pay periods a year (Monthly) [PDF] Last update: 2025-06-27 Related document: T4032 Payroll Deductions Tables Thank you for your feedback Page details Date modified: 2025-06-27 ...
Technical Interpretation - External
4 March 2025 External T.I. 2025-1053731E5 - DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement
4 March 2025 External T.I. 2025-1053731E5- DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement Unedited CRA Tags 87(4), 87(8), 87(8.4), 87(8.5). ... XXXXXXXXXX 2025-105373 Yannick Roulier March 4, 2025 Dear XXXXXXXXXX: Re: DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement We are writing in reply to your email dated February 14, 2025, in which you suggested that a particular statement made in the Department of Finance’s explanatory notes seems to be inconsistent with a technical reading of the legislation. ...
Decision summary
Pyxis Real Estate Equities Inc. v. Canada (Attorney General), 2025 ONCA 65 -- summary under Rectification & Rescission
Canada (Attorney General), 2025 ONCA 65-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission capital dividends were agreed to be paid in amounts that overlooked a CDA deficit: no rectification A plan was implemented for successive capital dividends to be paid up a chain of corporations so that the individual who was the ultimate shareholder could have a tax-free receipt of $1.4 million. ... …The corporate resolutions that were signed … accurately reflect the agreement. ...
Decision summary
PepsiCo, Inc v Commissioner of Taxation, [2024] FCAFC 86, aff'd [2025] HCA 30 -- summary under Payment & Receipt
PepsiCo, Inc v Commissioner of Taxation, [2024] FCAFC 86, aff'd [2025] HCA 30-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt there can be no payment by direction unless there is an antecedent obligation by the creditor to the third party A U.S. company (PepsiCo) entered into an “exclusive bottling appointment” (“EBA”) with an independent Australian bottling company (the “Bottler”) pursuant to which an Australian subsidiary of PepsiCo (the “Seller”) sold concentrate to the Bottler and PepsiCo granted the Bottler the right to use the Pepsi and Mountain Dew trademarks in connection with its sales of the soft drinks. Before finding that the payments made by the Bottler to the Seller were not derived by PepsiCo, so that the latter could not be subject to the Australian withholding tax on trademark royalties paid to a non-resident, Perram and Jackman JJ stated (at para. 40): It is well established that a direction by a creditor to a debtor to pay a third party constitutes a payment to the creditor. … Nevertheless, it is also recognised that there can be no payment by direction unless there is an antecedent monetary obligation owed by the Bottler to PepsiCo/SVC…. ...
Decision summary
Les Structures G.B. Inc. v. A.G. Canada, 2023 QCCS 3510, rev'd 2025 QCCA 134 -- summary under Rectification & Rescission
Canada, 2023 QCCS 3510, rev'd 2025 QCCA 134-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission transaction documents rectified because they did not implement the parties' intention to not trigger Part IV tax Four individuals held their indirect holdings of 10%, 10%, 5% and 5% of the common shares of a Canadian-controlled private corporation (Structures) through three holding companies (the "Holdcos"). ...
Decision summary
Agence du revenu du Québec v. Structures GB Ltée, 2025 QCCA 134 -- summary under Rectification & Rescission
Structures GB Ltée, 2025 QCCA 134-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission corporate reorganization documents could not be rectified to correct for an unforeseen Pt. ... (Canada), so that the rectification order was reversed, the Court stated (at paras. 25, 29-30, 36, TaxInterpretations translation): If the agreement is consistent with what the parties agreed to but simply produces unforeseen tax consequences, due to an error by the tax planners in the design of the tax planning, rectification cannot be granted. … The parties had not planned any specific entitlement [“prestation”] aimed at ensuring that Structures and the holding companies were connected throughout the 31 stages of the corporate reorganization of Structures. … … Mr. Côté, the tax specialist who conceptualized the reorganization, … affirmed that maintaining connectedness was not the object of the transaction, which was to crystallize as much CGD as possible.... ...
Decision summary
Bosa v Canada, 2025 BCSC 1284 -- summary under Rectification & Rescission
Bosa v Canada, 2025 BCSC 1284-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission BCSC lacked the jurisdiction to consider a request to rectify a clause in a family trust indenture whose interpretation was at issue in an impending TCC appeal The petitioners were the beneficiaries of a family trust, who sought to rectify the terms of the Trust Indenture to clarify that the assets of the trust had vested indefeasibly in them on the date defined in the Trust Indenture as the "Distribution Date," which occurred approximately 10 months before the 21st anniversary of the formation of the trust. ... Canada … 2013 ABQB 489, at para. 61. … The interpretation of the Trust Indenture which they [the petitioners] urge me to adopt is based on the same arguments that the Reassessment officer considered and rejected. Those arguments are the subject of the appeal to the Tax Court …. In further finding that, even if she had jurisdiction, rectification would not be appropriately granted, she stated (at para. 58) that “[i]t is well established that equitable relief is not available to avoid unanticipated adverse tax consequences which arise from the ordinary operation of the Income Tax Act … Collins Family Trust ….. ...
Current CRA website
Businesses – Tax information newsletter, Edition: 2025-03 – May 22, 2025
Businesses – Tax information newsletter, Edition: 2025-03 – May 22, 2025 Tariff support for your business As of April 2 until June 30, 2025, the CRA is deferring corporate income tax payments and GST/HST remittances. Interest will also be waived on new and existing GST/HST and T2 instalment and arrears payments due between April 2 and June 30, 2025. ... New business and program account registrations started May 12, 2025 Existing businesses start June 16, 2025 For more information, go to Online Mail for business. ...
Current CRA website
Businesses – Tax information newsletter, Edition: 2025-01 – January 9, 2025
Businesses – Tax information newsletter, Edition: 2025-01 – January 9, 2025 Business owners: Here’s what’s changing for taxes in 2025 Heads up, business owners! ... The first filing deadline for platform operators is January 31, 2025 for the 2024 calendar year. However, the CRA will be waiving penalties and interest for late filing until July 31, 2025. ...