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CRA further indicated that such “eligible medical expenses are not restricted to those paid in Canada or for medical services provided in Canada” – and that the insurer of the plan should determine whether this test in fact was being met. ...

CRA found that s. 93(4) applied to deny the loss and add it to the ACB to ACo of the shares of FA2 and FA3 on the basis that ACo had acquired those shares “on” its disposition of the shares of FA1 – even though such acquisition in fact occurred before the dissolution of FA1. ...

. … If it is determined that the transfer of property was a sale for inadequate consideration rather than a gift, paragraph 69(1)(c) would not apply. ...

If this requirement ceases to be met because the employer no longer wishes to make contributions, the plan will cease to qualify as an EPSP – and it will be a question of fact as to whether it thereafter becomes a salary deferral arrangement, retirement compensation arrangement or an employee benefit plan. ...

2 April 2019- 7:20pm CRA states that taxpayers should be able to handle the allocation of costs between pipelines and pipeline appendages Email this Content CRA noted that although its published policies distinguish between pipelines (Class 49 properties) and attachments to a pipeline that are not an integral and component part of the pipeline ("pipeline appendages") (which are often Class 7 properties), it has provided no “guidance as to how costs are allocated between pipelines included in class 49 and equipment included in class 7” – but went on to state: However, it is our understanding that there is sufficient information at the disposal of taxpayers, such as detailed engineering documents, progress reports, authorizations for expenditures and invoices, to enable a reasonable allocation of costs, including general contractor costs. ...

The “Manual used … [in] audits of small and medium-sized businesses does not contain any information on the application of subsection 55(2) and the purpose test, in particular.” ...

CRA indicated that since she satisfies the 20 hours per week test in s. 120.4(1.1)(a), her dividend income would be an excluded amount because it is derived from an excluded business – so that it would not be subject to the tax on split income. ...

Summary of 7 June 2019 STEP CRA Roundtable, Q.7 under s. 125(7) – specified investment business. ...

Subsection 146.2(2) provides that a “qualifying [TFSA] arrangement” must: (e) … provide that, at the direction of the holder, the issuer shall transfer all or any part of the property held in connection with the arrangement (or an amount equal to its value) to another TFSA of the holder; CRA apparently is reading into this wording a requirement that the arrangement represent transferable property. ...

8 July 2019- 12:55am CRA confirms that a Reg. 1103(1) election (consolidating in Class 1) does not affect subsequent years’ acquisitions Email this Content CRA effectively confirmed that Folio S3-F4-C1, para. 1.132 should be interpreted as having the bolded sentence below added to it: [U[nder [Reg.] 1103(1) …, a taxpayer may elect to transfer all properties otherwise included in Classes 2 through 12 (excluding Class 10.1) to Class 1 provided that all such properties were acquired for the purpose of gaining or producing income from the same business. ...