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17 August 2023- 11:37pm CRA indicates that s. 56(1)(r)(i) rather than s. 5(1) applies to inducement payments made by the government directly to a prospective hospital employee Email this Content CRA indicated that where a provincial government sponsors a program that is designed to deliver incentive payments or earnings supplements directly to eligible nurses, such amounts are included in their income under s. 56(1)(r)(i) (“earnings supplements provided under a [government-sponsored] project … to encourage individuals to obtain or keep employment”) whereas if it sponsors a program designed to have employers deliver the payments directly to them, such amounts are included in their employment income under s. 5(1). ...

After noting that the (apparently Quebec) statutory provisions governing an IMB are similar to those governing a CBCA corporation, including providing that the IMB is a legal person (“personne morale”), has limited liability, except in relation to certain borrowings, has a board of directors and is governed by by-laws and resolutions – and the interests in it carry voting rights, CRA concluded that such an IMB qualifies as a corporation. ...

11 September 2023- 12:37am CRA rules on a transfer of losses to a Profitco with a different functional currency Email this Content CRA ruled on transactions for the transfer of losses by Lossco to Profitco (a Canadian sister) by using standard triangular transactions- through Lossco subscribing for interest-bearing debt of (its new subsidiary) Newco 2, which subscribes for cumulative preferred shares of its sister, Newco 1, which makes a non-interest-bearing loan to Lossco, which at year end funds the dividend obligation of Newco 1 through a capital contribution – with the transactions then being unwound and with Newco 2 then being sold to Profitco so that Profitco can access the Newco 2 losses through winding-it up pursuant to s. 88(1.1). ...

Summary of PwC, “Tax Insights: Proposed changes to the alternative minimum tax ─ How will it affect individuals and trusts?” ...

CRA also noted that this situation could result in late-remittance penalties being levied in error – but that “these late-remitting penalties can be cancelled once the CRA is provided additional information regarding the timing of the payments made to the non-resident.” ...

Summaries of 1 May 2023 External T.I. 2021-0921101E5 under s. 149(1)(l), s. 149(12), s. 248(1) – disposition and s. 51. ...

If the IBT sale occurs for deferred purchase price (debt), the 10-year reserve proposed by s. 40(1.2) may allow the parent to avoid AMT entirely if the gain is small enough – but for larger sales, utilizing the 10-year reserve may trigger AMT in multiple years, reducing the parent’s ability to recover AMT. ...

. … Consequently, the Canada Revenue Agency will waive the application of penalties and interest for any late-filed UHT returns and for any late-paid UHT payable for the 2022 calendar year, provided the return is filed and the UHT is paid by April 30, 2024. ...

Consequently, subsection 55(2) should likely apply …. Neal Armstrong. ...

Summary of 2 November 2023 APFF Roundtable, Q.10 under s. 248(1) – disposition. ...