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28 July 2024- 10:43pm CRA finds that guaranteed salary payments received by a US-resident member of a Canadian team while not in Canada were not taxable in Canada Email this Content A resident of the US, who had entered into a 6-year employment contract with a Canadian team, suffered a serious injury in the 3 rd season but, pursuant to a guaranteed payment clause in his contract, continued to receive full salary for the remaining term of his agreement notwithstanding that he ceased playing for that team – and was released by that team, and hired by a US team in the 5 th season. ...

Summary of 2 April 2024 External T.I. 2024-1005231E5 under s. 118.1(1) – total charitable gifts. ...

Summary of 2022 Ruling 2022-0929431R3 F under s. 248(1) – corporation. ...

Summary of 10 October 2024 APFF Financial Strategies & Instruments Roundtable, Q.6 under s. 146.6(7). ...

Summary of 10 October 2024 APFF Financial Strategies & Instruments Roundtable, Q.10 under s. 148(7). ...

Summary of 4 June 2024 Underused Housing Tax (HST) Ruling 246073 under UHTA, s. 2 – owner. ...

V-VI-21 as the company failed to satisfy one of the stipulated conditions, namely, that the municipal “service is … one which the owner or occupant has no option but to receive” (presumably meaning that the company always had the “choice” of not proceeding with its expansion or somehow otherwise avoiding the additional sewage discharge). ...

Laplante, “Two Methods of Winding Up Mutual Fund Trusts,” Canadian Tax Focus, Vol. 15, No, 1, February 2025, p. 6 under s. 132(4) – CGR, and s. 132(5.3). ...

S. 143.2(15) provides that, notwithstanding ss. 152(4) to (5), “such assessments … may be made as are necessary to give effect to this section.” ...

Summary of 23 April 2024 External T.I. 2024-1004511E5 under s. 127(9) – qualified property- (c)(i). ...