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News of Note post
21 May 2025- 11:27pm CRA accepts capital gains and then capital loss treatment of an asset sale made on a reverse earnout basis, where the targets were not achieved Email this Content On the closing date for the sale by Opco of the assets, being capital property with an ACB of $150,000, of one of its two businesses to an arm's length purchaser, it was agreed that the purchaser: would pay $3,500,000 on the closing date, plus an adjustment a few months later (based on the finalized financial statements), which turned out to be $150,000; and would pay two further deferred amounts 12 and 18 months after the closing date of $300,000 and $200,000 if, in each case, the purchased business achieved targeted customer retention rates. 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. ... Summaries of 2 April 2025 External T.I. 2019-0818321E5 F under s. 12(1)(g) and s. 40(1)(a)(iii). ...
News of Note post
2 June 2025- 11:02pm CRA provides a formula for prorating foreign tax between a FAPI and non-FAPI business for FAT purposes Email this Content If a foreign affiliate (FA) carries on a business in a foreign county and pays tax to that country on income which the ITA segregates into income from a business other than an active business and active business income, how will the determination of what portion of the foreign tax paid “may reasonably be regarded as applicable to” foreign accrual property income (FAPI) of FA in accordance with the foreign accrual tax (FAT) definition be made? ... Summary of 28 May 2025 IFA Roundtable, Q.5 under s. 95(1) – FAT. ...
News of Note post
23 June 2025- 12:02am CRA refers to some guidelines applied by it in considering financial-hardship requests for excess withdrawals from a PGAP RDSP Email this Content For a registered disability savings plan (“RDSP”) that is a primarily government assisted plan (a “PGAP”), i.e., government contributions exceed plan holder contributions, annual withdrawals are limited to 10% of the value in the RDSP at the beginning of the year – except that CRA has indicated that it may permit withdrawal requests above that limit in circumstances of financial hardship where it is just and equitable to do so. ... Summary of 17 June 2025 STEP Roundtable, Q.5 under s. 146.4(4)(j). ...
News of Note post
10 July 2025- 12:15am CRA expands its discussion of crypto mining groups Email this Content CRA has published a revised version of its Notice on cryptoasset mining. ... Revised summaries of GST/HST Notice No. 324, "Mining Assets in respect of Cryptoassets" June 2025 under ETA s. 188.2(5) and s. 123(1) – consideration. ...
News of Note post
22 August 2025- 1:10am CRA reviews whether there can be an agreement for the sale of electricity between two carbon capture companies through a utility Email this Content Two companies (A and B) are each constructing, in Alberta, a “qualified CCUS project” as defined in s. 127.44(1). ... Summary of 5 June 2025 External T.I. 2025-1055221E5 under s. 127.44(1)- qualified carbon capture expenditure – s. ...
Current CRA website
Guide for the Partnership Information Return (T5013 Forms)
An enhanced first-year CCA rate is available as follows: 100% after March 18, 2019 and before 2024 75% after 2023 and before 2026 55% after 2025 and before 2028 For the enhanced first-year allowance, the following step should be done before calculating the CCA: increase the net capital cost addition to the new class for property that becomes available for use before 2028 as follows: For class 54, increase the capital cost addition by an amount equal to: 2 ⅓ times the net addition to the class for property that becomes available for use before 2024 1 ½ times the net addition to the class for property that becomes available for use in 2024 or 2025 5/6 times the net addition to the class for property that becomes available for use after 2025 and before 2028 For class 55, increase the capital cost addition by an amount equal to: 1 ½ times the net addition to the class for property that becomes available for use before 2024 7/8 times the net addition to the class for property that becomes available for use in 2024 or 2025 3/8 times the net addition to the class for property that becomes available for use after 2025 and before 2028 suspend the existing CCA half-year rule Multiply the result by the prescribed CCA rate of 30% for class 54 and 40% for class 55. ... Also includes heat recovery equipment for which the primary purpose is extracting heat for sale 30% 43.2 Clean energy generation and energy conservation equipment acquired before 2025. ... Line 430 – Non-arm's length debt owing and/or benefits receivable Enter the total of amounts " c " and " d " in the preceding formula. ...
News of Note post
16 March 2025- 11:49pm CRA indicates that individuals whose income is exempted under the Indian Act nonetheless are subject to the general T1135 and T1134 reporting obligations Email this Content CRA found that an “Indian” whose income earned during a taxation year is exempt pursuant to the Indian Act would be a “reporting entity” within the meaning of ss. 233.3 and 233.4 and, thus, be subject to the obligation to file T1135 and T1134 forms, and to penalties for failures to do so. ... Summary of 30 December 2024 Internal T.I. 2024-1031721I7 F under s. 233.3(1) – specified Canadian entity – (a)(iii). ...
News of Note post
31 July 2025- 12:20am CRA finds that card payment processing services paid by a merchant under an agreement with an ISO and credit card company were for exempt financial services Email this Content A merchant operating a convenience store entered into an agreement (the “Service Agreement”) with an independent sales organization (ISO) and an “acquirer” for the purpose of acquiring card payment processing services of the acquirer. ... Summary of 13 December 2024 GST/HST Ruling 247852 under ETA s. 123(1) – financial service – para. ...
News of Note post
4 August 2025- 11:29pm Luxembourg High Administrative Court indicates that a PE can ambulate within an office complex Email this Content A Luxembourg company (PSC) was unsuccessful in its arguments on appeal to the Luxembourg High Administrative Court that it acquired and held two companies through a permanent establishment (PE) in Malaysia. ... The group owned all or part of three office towers in a complex in Malaysia, and PSC argued that the office space allocated to its Malaysian branch could change from one tower to another depending on operational needs – so that the three towers should be considered a single site. ... Summary of Cour Administrative, Case no. 50602C 17 June 2024 (Luxembourg High Administrative Court) under Treaties – Income Tax Conventions – Art. 5. ...
News of Note post
7 April 2025- 11:22pm We have translated 8 more CRA interpretations Email this Content We have translated two CRA interpretations released last week and a further 6 CRA interpretations released in November and October of 2000. ... These are additions to our set of 3,159 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 24 ½ years of releases of such items by the Directorate. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2025-04-02 19 February 2025 External T.I. 2018-0744821E5 F- Régime d’assurance collective- groupe de personne Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) for a 2-person plan, a higher level of benefits for the majority shareholder would suggest that there was an individual policy for him, rather than being a group plan component Income Tax Act- Section 15- Subsection 15(1) rebuttable presumption that benefits of shareholder-employees from disability plan premiums were taxable/ meaning of "contemplated" shareholder 11 March 2025 External T.I. 2020-0845931E5 F- Transfert d’une propriété intellectuelle Income Tax Act- Section 9- Capital Gain vs. ...