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2 September 2020- 12:01am CRA indicates that accrual-basis taxpayers should not usually net bad or doubtful debt allowances against their qualifying revenues Email this Content Recently-enacted s. 125.7(4)(e)(ii) allows an eligible entity to elect “to determine its qualifying revenues based on … the accrual method, in accordance with generally accepted accounting principles. ...

This first note then is extinguished by operation of law when the portfolio company is wound-up into Newco a year later – with payments of the second note by Newco to the estate commencing thereafter. ...

CRA indicated that this position was contrary to Shell Canada, which found that absent a specific provision to the contrary or sham, the taxpayer’s legal relationships must be respected – so that withholding tax would not apply in such a situation absent a finding of sham or the application of a specific provision, e.g., s. 245 or 247. ...

Summary of 27 October 2020 CTF Roundtable, Q.8 under s. 248(1) – SDA. ...

CRA confirmed that for the purposes of the Act, and in the absence of a specific provision to the contrary such as s. 18(3), “a building or other structure affixed to land would generally be considered as part of the land,” so that “for the purposes of subsection 70(5.2) … ‘land’ includes not only vacant land, but also land on which other real property such as houses or condos are erected.” ...

CRA has clarified that this is incorrect – the election need only be made once (generally with the return for the project’s third taxation year). ...

CRA responded that the extensions accorded under the COVID-19 Time Limits Act did not apply here, and stated: [W]hile we understand that delays in the probate process may delay the timing of the disposition of the properties of an estate, the CRA is unable to extend the time limit for the dispositions in subsection 164(6) … beyond the first taxation year of the graduated rate estate. ...

Summaries of 15 December 2020 External T.I. 2020-0855601E5 under s. 125.7(1)- “qualifying revenue” – (c), (a)(ii). ...

Summary of 15 January 2021 External T.I. 2020-0847781E5 under s. 125.7(1) – Eligible Employee. ...

Summary of 7 October 2020 APFF Roundtable Q. 13, 2020-0852251C6 F under s. 125(7)- adjusted aggregate investment income – (a). ...