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Nonetheless, a Quebec general or limited partnership has many of the characteristics typically associated with legal personality such as being able or subject to suing or being sued in its own name, and having a separate patrimony – and CRA has “previously stated that the existence of a separate legal personality alone is generally not sufficient to distinguish certain foreign partnerships from Canadian partnerships.” ...

The Directorate indicated that FA4 appeared to have two separate businesses- a debt portfolio business, and a business of providing services to other foreign affiliates in the group – given inter alia that its services were mostly to other foreign affiliates (in contrast to the arm’s length customers of the debt portfolio business) and thus not principally services rendered to FA4’s own debt portfolio business. ...

Consequently, we remain of the view that any determination of whether section 9, paragraph 12(1)(x), or subsections 15(1), 56(2) or 246(1) of the Act apply to a particular shared-ownership arrangement involving life insurance policies and their respective premium payments can only be ascertained, on a case-by-case basis …. ...

Accordingly, an amount received by Spouse B from the Preference Shares would not constitute an “excluded amount” to Spouse B under paragraph (b) …. ...

CRA indicated that to the extent that the Government Assistance received by Aco was in respect of the acquisition of depreciable property (or land), s. 13(7.1) (or s. 53(2)(k)) will deem that amount to reduce the capital cost of the depreciable property (or land) – without any inclusion under s. 12(1)(x) pursuant to s.12(1)(x)(vi) and without any election required. ...

. … To the extent that an election is made under subsection 12(2.2), the inclusion under paragraph 12(1)(x) will be reduced pursuant to subparagraph 12(1)(x)(vii). ...

16 April 2024 Internal T.I. 2023-0964831I7- Guaranteed payments to non-resident athletes-- summary under Subparagraph 115(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(i) guaranteed salary payments received by a US-resident member of a Canadian team while not in Canada were not taxable in Canada A resident of the US, who had entered into a 6-year employment contract (covering years 20X1 to 20X6) with a Canadian team, suffered a serious injury in the 20X3 season but, pursuant to a guaranteed payment clause in his contract, continued to receive full salary for the remaining contract term notwithstanding that he ceased playing for that team – and was released by that team in 20X4 and hired by a US team in 20X5. ...

CRA indicated that such a deemed resident trust is not subject to Part XIII tax on amounts paid or credited to it, but is not considered to be resident in Canada for the purposes of determining the liability of a person other than the trust to withhold and remit under s. 215 – so that there is still a requirement to withhold and remit Part XIII tax on the rent paid to such trust. ...