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11 July 2025- 12:06am CRA finds that wind turbine workers are not Red Seal workers for ITC purposes Email this Content Wind turbine workers who install a company’s wind turbines on a project perform a variety of specialized duties, including some duties that could theoretically be otherwise performed by construction craft workers, millwrights and concrete finishers, but their duties in fact are not performed by such tradespeople, nor by any other federally, territorially or provincially-registered tradespeople. ... Summary of 23 April 2025 External T.I. 2024-1046391E5 under s. 127.46(1) – red seal worker. ...

19 August 2025- 11:16pm BMO- Tax Court of Canada finds that arrears interest on US assessments of US branch taxes was non-deductible in computing BMO’s income Email this Content BMO was assessed in 2004 and 2006 for additional U.S. federal (and NYC) income tax and interest on business profits attributed to its US branch operations for its 1997 to 2001 taxation years. ... The King, 2025 TCC 113 under s. 18(1)(a) – income-producing purpose. ...

25 August 2025- 11:53pm Reporting platform operators may be required to infer the consideration paid to platform vendors from the dollar value of their orders Email this Content The operator of a proprietary digital platform, who was also an equipment manufacturer, allowed independent vendors to list their goods for sale on the platform to select customers. ... Summaries of 30 May 2025 External T.I. 2025-1050201E5 under s. 288(1), s. 282(1) – consideration, active seller. ...

5 June 2025- 11:13pm CRA rules on qualification of building an access road as CEE Email this Content In order to facilitate access of exploration drilling equipment to a deposit, the taxpayer (a principal business corporation) will be constructing a one-way gravel road to the site. ... Summary of 2024 Ruling 2024-1017941R3 under s. 66.1(6) – CEE – (f). ...

21 January 2025- 11:31pm CRA releases a new Memorandum on the IPP provincial place-of-supply rules Email this Content CRA has published a GST/HST Memorandum (supplanting draft B-103) on the rules (other than some specialized rules) governing the determination of the province of supply of intangible personal property. ... Summaries of GST/HST Memorandum 3-3-5 “Place of Supply in a Province – General Rules for Intangible Personal Property” January 2025 under New Harmonized Value-Added Tax System Regulations, s. 2 – Canadian rights, s. 6(1), s. 6(2)(a), s. 6(2)(b)(i)(A), s. 6(2)(b)(i)(B), s. 6(2)(b)(i)(C), s. 6(2)(c), s. 8(b)(i)(A), s. 8(b)(i)(B) and s. 11. ...

27 January 2025- 11:30pm We have translated 7 more CRA interpretations Email this Content We have translated a CRA interpretation released last week and a further 6 CRA interpretations released in February of 2001. ... These are additions to our set of 3,090 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ¾ years of releases of such items by the Directorate. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2025-01-22 7 January 2025 External T.I. 2022-0945291E5 F- Intérêts versés sur des obligations communautaires d’une coopérative Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(l) members providing legitimate debt financing of an NPO can be consistent with the s. 149(1)(l) conditions/ preferred shares that can bear “interest” cannot be issued 2001-02-16 1 February 2001 External T.I. 2000-0008675 F- Avantage-société devenue imposable Income Tax Act- Section 15- Subsection 15(1) inevitable s. 15(1) benefit when not-for-profit with surplus is converted to a share corporation and the members subscribe for shares 1 February 2001 External T.I. 2000-0049655 F- Transfert entre conjoints de crédit d'impôt Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Cultural Gifts credits from gifts of cultural property can be reallocated between spouses, but s. 69 gains cannot be reallocated 6 February 2001 External T.I. 2000-0060435 F- Exclusion des frais d'exploration Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (k.1) ATV was excluded 29 January 2001 Internal T.I. 2000-0062827 F- Placement admissible- conjoint de fait Income Tax Regulations- Regulation 4901- Subsection 4901(2)- Connected Shareholder RRSPs of two individuals prior to their marriage were not necessarily not dealing at arm’s length 2001-02-02 1 February 2001 External T.I. 2000-0041535 F- Actionnaire rattaché / droit de 1er refus Income Tax Regulations- Regulation 4901- Subsection 4901(2.2)- Paragraph 4901(2.2)(b) comments in IT-419R, para. 13 re shotgun clauses etc. are applicable to Reg. 4901(2.2)(b) 31 January 2001 External T.I. 2000-0050465 F- TRANSFERT D'UN BIEN AGRICOLE Income Tax Act- Section 73- Subsection 73(3) immediately “before the transfer” referenced a period of less than three years ...

1 January 2025- 11:35pm CRA finds that the property of an alter ego trust “belonged” to its sole trustee and life beneficiary rather than to the trust Email this Content In order for a fee paid to a corporation for the executive producer servicers of an individual employed by the corporation to qualify for the B.C. production services tax credit, there was a requirement (essentially copied from ITA s. 125.4(1) – labour expenditure – (b)(iii) and s. 125.5(1) – Canadian labour expenditure- (b)(iii)) that the shares of the corporation “belong” to a BC-based individual – whereas, here, the shares were held by the individual in his capacity of trustee of an alter ego trust which had been settled by him (to avoid B.C. probate duties) and of which he was the life beneficiary. ... [Here] … [the individual] has legal ownership of the shares in [the individual’s] role as trustee, and beneficial ownership of the shares as the sole beneficiary who is entitled to the income on the shares while [the individual] is alive …. ... Summary of 9 July 2024 Internal T.I. 2023-0976691I7 under s. 125.4(1) – labour expenditure – (b)(iii). ...

8 January 2025- 11:26pm The concept of de facto control should not have an expansive meaning in the context of the s. 84.1(2.3) rules Email this Content The immediate intergenerational transfer rules in s. 84.1(2.31) require the parents to give up de facto control of the business immediately after the disposition time, while allowing them to retain “management” of the business for up to three years after the disposition time. ... Langlois, which found that a 50% shareholder who had “an operational role, not a decision-making role” was not part of the de facto control of the corporation, whereas the other shareholder, who “[a]s the sole director … had the power that ensured him a dominant influence in the direction of the [corporation]” had de facto control. ... The Meaning of “De Facto Control” in the Context of Subsection 84.1(2.31),” Tax for the Owner-Manager, Vol. 25, No. 1, January 2025, p. 1 under s. 84.1(2.31)(c). ...

19 May 2025- 11:17pm Maple Leaf Foods is proposing to spin-off its pork assets as Canada Packers Email this Content Maple Leaf Foods (or MLF) is proposing to effect a butterfly spin-off, pursuant to a CBCA Plan of Arrangement, of 84% of the shares of the subsidiary (Subco) containing its pork operation assets to a new corporation, named Canada Packers Inc., to be held by its shareholders (with the remaining 16% of Canada Packers being held by MLF). ... Summary of May 1, 2025 Circular of Maple Leaf Foods Inc. under Spin-offs and Distributions – Butterfly spin-offs. ...