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25 February 2025- 11:26pm CRA confirms that, in Audit’s discretion, it may provide relief where GST/HST has been double-collected Email this Content A resident proprietor provided short-term accommodation through the platform of a non-resident company and, as a GST/HST “regular” registrant, charged and collected GST/HST on the rentals. ... Policy Statement P-131R is subject to certain exceptions and its application is at audit's discretion at the time of an audit …. ... Summary of 18 July 2024 GST/HST Interpretation 245851 under ETA s. 211.13(3) and s. 225(1) – A(a), ...

6 January 2025- 11:16pm CRA finds that the merchant rather than the consumer was the recipient of delivery services for goods sold through a platform Email this Content Consumers purchased goods from merchants through a platform which acted as facilitator, and as collection agent on behalf of the merchant and delivery drivers. ... Summary of 17 July 2024 GST/HST Ruling 219794 under ETA s. 123(1) – recipient. ...

14 April 2025- 11:35pm We have translated 8 more CRA severed letters Email this Content We have translated a CRA interpretation and ruling released last week and a further 6 CRA interpretations released in October and September of 2000. ... These are additions to our set of 3,167 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 2025-04-09 2024 Ruling 2023-0998291R3 F- Multi-wings split-up net asset butterfly 55(3)(b) Income Tax Act- Section 55- Subsection 55(1)- Distribution split-up butterfly between a divorced couple where excess debt is allocated to land rather than building to produce capital gains treatment Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(b) excess debt allocated on s. 85(1) transfer of land and building to the land so as to produce capital gains rather than recapture 17 January 2025 Internal T.I. 2024-1029791I7 F- SSUC- Rémunération de la haute direction / CEWS- Income Tax Act- Section 125.7- Subsection 125.7(1)- Executive Remuneration no adjustments are made to an eligible entity's Statement of Executive Compensation for NEOs filed pursuant to NI 51-102 for CEWS repayment purposes Income Tax Act- Section 125.7- Subsection 125.7(14) repayment based on NI 51-102 statements, without adjustments 2000-10-13 18 September 2000 External T.I. 2000-0026805 F- PAIEMENTS DANS LE CADRE D'UN CONGEDIEMENT Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance payment in lieu of reasonable notice was s. 5 employment income Income Tax Regulations- Regulation 102- Subsection 102(1) reimbursed legal costs of dismissed employee paid by the employer are not subject to withholding if such costs were deductible under s. 8(1)(b) 3 October 2000 Internal T.I. 2000-0039997 F- VENDEAU-CONFERENCE ET CONGRES Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(f)- Subparagraph 8(1)(f)(v) costs of presentations to improve skills of salespeople who generated commissions to the taxpayer were not capital expenditures, cf. cost of attending conference 20 September 2000 External T.I. 2000-0043435 F- Associé quittant société de personnes Income Tax Act- Section 53- Subsection 53(1)- Paragraph 53(1)(e)- Subparagraph 53(1)(e)(i) adjustments to avoid double taxation on a completed withdrawal from a partnership are considered first by the TSO, generally as part of an audit 2000-09-29 14 September 2000 External T.I. 2000-0037085 F- ALLOCATION DE RETRAITE Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance a lump sum amount paid in satisfaction of salary insurance benefits could not be transmuted into a retiring allowance Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) a lump sum paid in satisfaction of an insurer's obligations under a wage loss replacement plan were taxable irrespective of whether paid as a lump sum and via the employer Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) lump sum wage loss payments paid by an insurance company to the employer for on-payment were subject to source deductions 14 September 2000 External T.I. 2000-0023515 F- TAXE DE VENTE AVANTAGE IMPOSABLE Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) payment by employer of sales tax on insurance premiums under an employee-funded sickness or accident insurance plan did not taint the plan Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) payment by employer of sales tax on insurance premiums under an employee-funded sickness or accident insurance plan is a taxable benefit 2000-09-15 11 September 2000 External T.I. 2000-0045115 F- FERR TRANSFERT Income Tax Act- Section 60- Paragraph 60(l) an individual's spouse may make a transfer from a spousal RRIF a non-spousal RRIF of the spouse (which then becomes a spousal RRIF) Income Tax Act- Section 146.3- Subsection 146.3(5.1) spousal RRIF status has relevance only for purposes of s. 146.3(5.1) ...

29 April 2025- 3:50am 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 September of 2000. ... These are additions to our set of 3,182 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 2025-04-23 4 January 2022 External T.I. 2016-0644861E5 F- Travail de nature temporaire Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) the "duties … of a temporary nature" condition is tested on a site-by-site basis 28 March 2025 External T.I. 2016-0662951E5 F- Alinéa b) de la définition d’action admissible de Income Tax Act- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share- Paragraph (b) settling QSBCS shares on a personal trust with related beneficiaries before a sale of those shares 6 months’ later would not cause QSBCS status to be lost Income Tax Act- Section 110.6- Subsection 110.6(14)- Paragraph 110.6(14)(f) settling QSBCS shares on a personal trust whose beneficiaries were related as required by s. 110.6(14)(c)(ii) permitted a sale thereafter without loss of QSBCS status 2000-09-15 29 August 2000 Internal T.I. 2000-0023187 F- Société privée sous contrôle canadien Income Tax Act- Section 125- Subsection 125(7)- Canadian-Controlled Private Corporation ultimate control of Opco was held by Pubco through an indirect wholly-owned subsidiary that was the general partner of an LP holding 2/3 of Opco’s voting shares Income Tax Act- Section 251- Subsection 251(2)- Paragraph 251(2)(b)- Subparagraph 251(2)(b)(i) GP generally controls a corporation whose voting control is held by a limited partnership 16 September 1999 Internal T.I. 9913460 F- CONF. ...

22 April 2025- 10:15am 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 September of 2000. ... These are additions to our set of 3,174 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 2025-04-16 4 March 2025 External T.I. 2024-1009691E5 F- Bump and Qualifying Exchange Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c) a s. 132.2 exchange of MFC shares for MFT units precluded a s. 88(1)(d) bump of the MFT units 2000-09-15 7 September 2000 External T.I. 2000-0015905 F- allocation pour repas Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii) allowance is reasonable if it is determined on the basis of an estimate of the average costs incurred by employees on a regular basis 7 September 2000 External T.I. 2000-0017015 F- CALCUL DE LA SURTAXE Income Tax Act- Section 180.1- Subsection 180.1(2) surtax computed on the higher of the Division E and E.1 amounts, both computed before deduction of the foreign tax credit and overseas employment tax credit 7 September 2000 External T.I. 2000-0018585 F- FRAIS DE STAGE COOPERATIF Income Tax Act- Section 118.5- Subsection 118.5(1)- Paragraph 118.5(1)(a) co-op placement fees were not tuition 8 September 2000 External T.I. 2000-0023475 F- INDIEN EMPLOYE MIN AFFAIRS INDIENNES Other Legislation/Constitution- Federal- Indian Act- Section 87 earnings of a status Indian employed off-reserve by the Department of Indian and Northern Affairs were not exempted 13 September 2000 Internal T.I. 2000-0027557 F- REER AU PROFIT DU CONJOINT Income Tax Act- Section 146- Subsection 146(1)- Spousal or Common-Law Partner Plan- Paragraph (a)- Subparagraph (a)(ii) no extension of the rule to a transfer from spousal plan via an RPP to the taxpayer’s RRSP, but GAAR might apply 31 August 2000 Internal T.I. 2000-0038757 F- ALLOCATIONS POUR FRAIS DE DEMENAGEMENT Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b) first $650 of formula moving allowance (e.g., 2 weeks’ salary) was to be excluded from employment income ...

26 May 2025- 10:52pm 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 August of 2000. ... These are additions to our set of 3,209 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 2025-05-21 2 April 2025 External T.I. 2019-0818321E5 F- Reverse Earnout Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) capital gains and then capital loss treatment of an asset sale made on a reverse earnout basis accepted, where the targets were not achieved Income Tax Act- Section 40- Subsection 40(1)- Paragraph 40(1)(a)- Subparagraph 40(1)(a)(iii) no capital gains reserve is available for a reverse earnout 2000-08-04 14 July 2000 External T.I. 2000-0015245 F- ÉTUDIANT A TEMPS PLEIN- T2202A Income Tax Act- Section 118.5- Subsection 118.5(1)- Paragraph 118.5(1)(b) following of institution's policy for recognizing full-time students 10 July 2000 Internal T.I. 2000-0022027 F- OBLIGATION LÉGALE DE PAYER UNE DÉPENSE Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) not contingent if only uncertainty as to timing of payment and not as to obligation to pay 10 July 2000 Internal T.I. 2000-0022907 F- Allocation de fin de carrière- revenu gagné Income Tax Act- Section 146- Subsection 146(1)- Earned Income “end-of-career” allowances received by physician were earned income given his continued work 5 July 2000 Internal T.I. 2000-0024977 F- PENSION ALIMENTAIRE- DATE D'EXECUTION Income Tax Act- Section 56.1- Subsection 56.1(4)- Commencement Day interim support order that replaced separation agreement established a commencement day 5 July 2000 Internal T.I. 2000-0025487 F- PENSION ALIMENTAIRE Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount- Paragraph (a) written agreement must be what established the support obligation 23 September 1998 External T.I. 9800555 F- FIDUCIE SUCCESSIVE- FIDUCIE TESTAMENTAIRE Income Tax Act- Section 248- Subsection 248(9.1) trusts for the minor children which, by will, were to receive a gift over of the remainder from a spousal trust established by that will, were deemed by s. 248(9.1) to be testamentary trusts Income Tax Act- Section 108- Subsection 108(1)- Testamentary Trust remainder trusts required by the will to be established for the children after the termination of the testamentary spousal trust were deemed to be testamentary trusts by s. 248(9.1) ...

8 July 2025- 12:13am 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 June of 2000. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2025-07-02 29 April 2025 External T.I. 2024-1036641E5 F- Relevant Group Entity Income Tax Act- Section 84.1- Subsection 84.1(2.31)- Paragraph 84.1(2.31)(c)- Subparagraph 84.1(2.31)(c)(iii) a Realtyco, whose shares qualified as QSBCS based on a related corporation’s active business, would be a “relevant group entity” on a sale of the latter’s shares Income Tax Act- Section 84.1- Subsection 84.1(2.32)- Paragraph 84.1(2.32)(c)- Subparagraph 84.1(2.32)(c)(iii) continued control of the related lessor to an Opco would violate the s. 84.1(2.32)(c)(iii) condition on a sale of Opco to a child’s purchaser corporation 2000-06-23 10 May 2000 Internal T.I. 2000-0016257 F- RPA COTISATIONS POUR SERVICES ANTERIEURS Income Tax Act- Section 147.2- Subsection 147.2(4)- Paragraph 147.2(4)(c) no retroactive deduction 19 May 2000 Internal T.I. 2000-0018477 F- DEDUCTION A LA SOURCE Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(j) amounts paid out of RRSP to trustee in bankruptcy pursuant to judgment were subject to source deductions even though no mention thereof in court order 2000-06-09 8 June 2000 External T.I. 1999-0006105 F- TRANSFERT DE BIENS A UN CONJOINT Income Tax Act- Section 74.1- Subsection 74.1(1) CCRA has not yet developed a position re where the transferred property itself is returned to the transferor spouse in repayment of the transferee spouse’s debt 15 May 2000 Income Tax Severed Letter 2000-0008210 F- ADMINISTRATEUR DE FACTO Income Tax Act- Section 227.1- Subsection 227.1(1) individual can be a de facto director who acts as such with the shareholders’ agreement or takes significant actions with 3rd parties in the corporation’s name 31 May 2000 External T.I. 2000-0009695 F- FRAIS MEDICAUX-PREPOSE A PLEIN TEMPS Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(b) meaning of “one full-time attendant … for the full-time care of the individual” 5 June 2000 External T.I. 2000-0010615 F- Developpement d'un equipement- RS&DE Income Tax Act- Section 37- Subsection 37(8)- Paragraph 37(8)(d) expenditures to develop SR&ED equipment could be current expenses ...