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News of Note post
22 August 2019- 12:48am CRA indicates that rent for fully-furnished apartments is all rent Email this Content CRA indicated that all of the rent generated from a rental unit that was fully-furnished with “furnishings typically found in a residence” would qualify as “rent from real or immovable properties” for these purposes, assuming that there was a single charge that did not allocate anything to the furnishings. ...
News of Note post
26 August 2019- 11:13pm CRA comments on “qua employee” status where the individual also acquires 3% of the shares Email this Content A general response to a question as to whether a new CEO of a CCPC was receiving a housing loan qua employee (so that s. 15(2.4)(b) could apply) given that he also was acquiring 3% of the corporation’s shares may imply that CRA was not startled by the proposition that this was the case, stating: [G]enerally “benefits” are received qua shareholder where that person can significantly influence the corporation’s business policy. ...
News of Note post
18 October 2019- 12:10am CRA indicates that s. 60(o)(i) generates professional fee deductibility from the moment that CRA informs that there is an audit Email this Content CRA considers that “subparagraph 60(o)(i) applies to [accord deductibility to] fees or professional fees incurred as part of an audit from the time that the taxpayer was informed that the taxpayer was subject to an audit or new examination respecting the taxpayer’s tax return” as well as to “the professional fees or expenses incurred to mount a challenge before the Administrative Tribunal of Québec following a decision rendered by Retraite Québec concerning the tax credit granting an allowance to families” but that “professional fees or expenses incurred to make a claim for interest and penalty relief [are] not deductible.” ...
News of Note post
Summary of 11 October 2019 APFF Financial Strategies and Instruments Roundtable, Q.7 under s. 207.01(1)- “exempt contribution” (b). ...
News of Note post
VI, ss. 18 and 17 describe a GST/HST exemption for a supply of a membership in a professional organization or a public sector body in qualifying circumstances unless an election is made (on Form GST 124 or GST23, respectively) for s. 18 or 17 to not apply to the supply. ...
News of Note post
Summaries of 28 February 2019 CBA Roundtable, Q.12 under ETA s. 221(2) and General Concepts Agency. ...
News of Note post
In response to a question as to whether a participant in a joint venture includes a person who contributes solely property management services to the joint venture pursuant to a written joint venture agreement, CRA responded: We are currently reviewing the extent to which the Medallion decision would affect our position with respect to the issue of who can be considered to be a participant in a joint venture for purposes of section 273 …, and this includes taking into consideration the issue described in the question. ...
News of Note post
21 November 2019- 1:59am An employer is more exposed to CPP and EI assessments than for income tax source deduction assessments Email this Content Two differences between an employer’s income tax, and CPP and EI, withholding or remittance obligations: If the employer misses the 90-day deadline to file an appeal to the Tax Court from an income tax assessment, it can file an application for a one-year extension under ITA s. 167(5) whereas there is no such potential extension under the EI Act or CPP Act. ...
News of Note post
15 January 2020- 11:31pm CRA finds that compensation received by residential tenants from a developer to compensate them for their dislocation costs was non-taxable Email this Content The City required a developer to pay tenants, whose units in a residential complex were to be replaced or renovated, (at their option) lump sums to compensate them for their moving and relocation expenses, or a supplement equal to their additional rental cost (subject to a cap) while they were awaiting a return to the developed complex without being subject to any means testing. ...
News of Note post
MacPhee J found that the filing of the extension application was insufficient to consider that the proceeding (the appeal) had been launched before the dissolution and essentially followed 1455257 Ontario in finding that the Manitoba statute “does not allow a dissolved corporation to initiate a civil procedure.” ...

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