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Summaries of Folio S3-F3-C1 dated 8 April 2019 under s. 13(4.1), s. 13(4.3), s. 44(1), s. 44(1)(e), s. 44(5)(a), s. 44(6), s. 248(1) – former business property, s. 87(2)(l.3) and s. 88(1)(e.2). ...

V, Pt, II, s. 5, depending on who accompanied the patient – whereas if the attendants were paramedics it would not be exempted. ...

Summary of 15 May 2019 IFA Roundtable, Q.8 under Treaties – Income Tax Conventions- Art. 29A. ...

16 July 2019- 11:44pm CRA indicates that tax paid in error does not figure into the SAM formula for SLFIs Email this Content The special attribution method formula in ETA s. 225.2(2), as modified by the Selected Listed Financial Institution Attribution Method (GST/HST) Regulations, requires a SLFI to apply a weighted average provincial HST rate (determined based on the relative provincial weightings of its stakeholders) to the net federal GST “payable” by it under A of the formula to arrive at the level of provincial HST that normatively should have been payable by it, and to then compare this normative provincial HST to the actual provincial HST “payable” by it (under element F of the formula) to determine whether it is entitled to a refund or is obligated to make a top-up payment – subject to the making of special adjustments under element G of the formula, and subject to further elaboration for Quebec. ...

The spin-off mechanics were conventional, and at their conclusion, there were two promissory notes for $30M owing by Oldco and Newco to each other – which then were set-off. ...

This created a problem for its ability to elect under (c)(i) of the definition of “public corporation” in s. 89(1) to cease to be a public corporation- which was that it did not literally satisfy the requirement in Reg. 4800(2)(a)(i) that “insiders of the corporation shall hold more than 90 per cent of the issued and outstanding shares of each class … that was, at any time after the corporation last became a public corporation, listed on a designated stock exchange in Canada [or of designated surrogate qualified-for-distribution shares under Reg. 4800(2)(a)(ii)].” ...

Summary of 8 August 2019 Internal T.I. 2018-0776661I7 under s. 9 – computation of profit. ...

. … [I]t is likely that the employer is the primary beneficiary of an employee’s travel to and from home in between the first and last call out of a standby shift. ...

10 October 2019- 12:44am CRA applies its view that a partner is attributed each PE of a partnership for Reg. 400/403 purposes Email this Content Under Regs. 403(1) and (3), a property insurer (or, in this case, a reinsurer) is required to allocate its taxable income to the provinces on the basis of the respective proportions of its net property insurance premiums that are arrived at by allocating its net premiums to the provinces where the insured property is situate – except that if it does not have a permanent establishment in a particular province, the net premiums for the insured property in that province are allocated to the province which has a PE to which those net premiums are “reasonably attributable.” ...

. … [T]he safe income attributable to the shares of the capital stock of Holdco should be $900,000, which is the safe income attributable to the shares of the capital stock of Opco 1 held by Holdco. ...