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Summary of 6 January 2020 External T.I. 2019-0800941E5 under s. 9 – computation of profit. ...

However, CRA added that “[w]hether the allowance is reasonable … would need to be assessed on a case by case basis.” ...

Summary of May 2019 CPA Alberta CRA Roundtable, GST Session – Q.4 under ETA s. 156(4)(b)(ii). ...

Summary of May 2019 CPA Alberta CRA Roundtable, GST Session – Q.7 under ETA s. 285. ...

Summary of May 2019 CPA Alberta CRA Roundtable, GST Session – Q.10 under ETA s. 256.2(7). ...

Summary of May 2019 CPA Alberta CRA Roundtable, GST Session – Q.20 under ETA s. 156(4). ...

As such … it is not possible for a foundation to make a gift to a qualified donee in the course of carrying on of its own charitable activities. ...

However … [i]n this particular [COVID] context, the Canada Revenue Agency is prepared to accept that the reimbursement, upon presentation of supporting documentation, of an amount not exceeding $500, of all or part of the cost of acquiring personal computer equipment to enable the employee to immediately and properly perform the employee’s work, is primarily for the benefit of the employer, so that it does not result in a taxable benefit to the employee. ...

However, since the joint election must be made with all group members, the qualifying revenue of each one should be examined – for example, the passive income of the individual’s spouse. ...

6 August 2020- 11:36pm Supreme Court grants leave in Alta Energy Email this Content Alta Energy rejected what essentially was a Crown position that Treaty-shopping (here, transferring an investment in a Canadian resource company to a Lux holding company followed by a sale, two years later, that was Treaty-exempt) was a GAAR abuse – with Webb JA saying, for instance that there “is no distinction in the Luxembourg Convention between residents with strong economic or commercial ties and those with weak or no commercial or economic ties,” and that “the object, spirit and purpose of the relevant provisions of the Luxembourg Convention is reflected in the words as chosen by Canada and Luxembourg.” ...