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Summary of 16 July 2021 Internal T.I. 2020-0872521I7 under s. 125.7(1)- “qualifying rent expense” – para. ...

4 August 2021- 10:59pm CRA applies Ensite in determining whether assets are “used in the course of carrying on business” Email this Content One of the requirements for the continuity rule in s. 127.5(4.2) to apply where there has been an acquisition by an eligible entity of assets from a seller with whom the eligible entity did not deal at arm’s length is that (per s. 125.7(4.1)(b)(i)) “immediately prior to the acquisition, the fair market value of the acquired assets constituted … all or substantially all of the fair market value of the property of the seller used in the course of carrying on business.” ...

GST/HST Memorandum17-13 [17.13] Application of Section 141.02 to Financial Institutions That Are Qualifying Institutions, 23 July 2021 under s. 141.02(1) – exclusive input, direct input, s. 141.02(8) and s. 141.02(32). ...

Summary of 10 August 2021 Short Form Base Shelf Prospectus of Sprott Physical Uranium Trust under Commodity Funds – Metals Funds. ...

CRA ruled that the pref redemption would not reduce the safe income on hand attributable to the common shares – noting in its summary that this was because there was no inherent gain on such pref. ...

On a subsequent third-party sale by the trust of those shares, the QSBC definition requires that the shares have been owned by the trust, or a person related to the trust, for the prior 24-month period – and in this regard, s. 110.6(14)(c)(ii) provides that where a person who sold shares to a trust was related to all the beneficiaries, that person and the trust are deemed to have been related for the above purpose. ...

CRA stated: If the facts and circumstances of a specific case demonstrate that the financial dependence of one party on another is such that it is possible for the CRA to conclude that a transaction or series of transactions was entered into between persons not dealing with each other at arm's length under any of the criteria listed in … S1-F5-C1, [para. 1.38, respecting a common mind directing the bargaining, acting in concert or de facto control], then such dependence may be sufficient to conclude that the parties are not dealing at arm's length. ...

IV tax under s. 186(1)(b) in the hands of Holdco – so that the exclusion in the preamble to s. 55(2) applies to the extent that such Pt. ...

Summary of 2021 APFF Financial Strategies and Instruments Roundtable, Q.3 under s. 54 – superficial loss. ...

Summary of Tu Vu, “Application of Disproportionate UFT Election,” Canadian Tax Focus, Vol. 11, No. 4, November 2021, p. 15 under Reg. 5907(1)- underlying foreign tax applicable – para. ...