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. … (e) The later accounting of the transactions by all parties is as if the election was made … 57. A request will not be accepted in the following cases: (a) It is reasonable to conclude that the taxpayer made the request for retroactive tax planning purposes. … (c) It is reasonable to conclude that the taxpayer had to make the request because he or she was negligent or careless to comply with the law ...

. … The grant or transfer of the legal ownership of an equitable interest in real property may, therefore, be considered a "sale" of real property. … Where such grants or transfers are considered a "sale", the self-assessment rules of subsection 221(2) of the Act would apply. ... The consideration paid for the actual grant of the interest may be considered as being in respect of the sale of the interest where there is no consideration related to the actual use of the underlying property. … ...

. … The grant or transfer of the legal ownership of an equitable interest in real property may, therefore, be considered a "sale" of real property. … Where such grants or transfers are considered a "sale", the self-assessment rules of subsection 221(2) of the Act would apply. ... The consideration paid for the actual grant of the interest may be considered as being in respect of the sale of the interest where there is no consideration related to the actual use of the underlying property. … ...

GST60 GST/HST Return for Purchase of Real Property or Carbon Emission Allowances-- summary under Paragraph 228(4)(b) Summary Under Tax Topics- Excise Tax Act- Section 228- Subsection 228(4)- Paragraph 228(4)(b) Use this return to report and pay the goods and services tax/harmonized sales tax (GST/HST) when you purchase taxable real property (for example, land or a building) or you purchase taxable supplies of emission allowances (see page 3 for definition) that are made in Canada, and you are in any of the following situations: • You are registered for the GST/HST and the use or supply of the real property or emission allowances in your commercial activities will be 50% or less. • You are not registered for the GST/HST and you purchased the real property from a person who is not resident in Canada, or from a person who is considered to be resident only for activities carried on through the person's permanent establishment in Canada. • You are not registered for the GST/HST and you purchased taxable supplies of emission allowances that are made in Canada ...

At the time of this election, for each class of shares referred to in 2 above: • insiders of the corporation must hold more than 90% of the issued and outstanding shares • the corporation must have: –in the case of equity shares, less than 50 shareholders, other than insiders –in any other case, less than 100 shareholders, other than insiders • except for insiders, each shareholder or group of shareholders must hold at least one block of shares having a fair market value of at least $500 Attach a list of shareholders who are insiders and their shareholdings. ...

CRA Webpage, Enhanced reporting rules for trusts and bare trusts: Frequently asked questions, updated on 14 March 2025-- summary under Subsection 163(5) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(5) s. 163(5) gross negligence penalty could be imposed for failure to file a return 1.10 … Errors or omissions may be identified by the CRA based on a review of the information filed. If the trust is not a listed trust and a person knowingly or under circumstances amounting to gross negligence makes, — or participates in, assents to or acquiesces in, the making of — a false statement or omission on a return required to be filed, or fails to file a return, a penalty may apply under subsection 163(5). ...

Non-compliance is normally discovered by a Senior Officer Trade Compliance (SOTC) as a result of an audit, examination, verification, or subsequent monitoring activity. … Contravention C353 applies only in cases where customs duties and/or taxes are payable by the importer as a result of the correction. ... Errors discovered during a second or subsequent audit, examination, verification, or monitoring activity that are unrelated to the first penalty assessment will incur only first level penalties. …. ... For example, packaging or assists provisions; (b) formal assessment documents issued by the Canada Border Services Agency (CBSA) to the importer, relating to the imported goods, such as determinations (other than “deemed determinations”), re-determinations, further re-determinations, etc.; … (e) written communication addressed directly to the importer or the importer’s agent from the CBSA such as a national customs ruling, or a trade compliance verification final report; … First Level Penalties … For errors that have occurred as a result of reason to believe criterion (a): First level penalties that are the result of criterion (a) will be assessed on a per issue basis for each issue not corrected within 90 days of having “reason to believe”. ...

. … As the stewardship fee is a "provincial levy" for purposes of section 154 that is imposed on and payable by the manufacturer (that is, the supplier) on its supply of the tires, under subsection 154(2), this fee is included in the consideration for the supply of the tires by the manufacturer to the retailer. ... The retailer’s invoice to the customer includes $520 ($130 × 4) for the tires and an additional $19.20 ($4.80 × 4) which it separately lists as a stewardship fee representing the cost to the retailer of the stewardship fee passed on by the manufacturer.…. ... A motor vehicle owner in the province purchases 30 litres of gasoline. … The carbon tax is a provincial levy as defined in subsection 154(1) and is payable by the purchaser/recipient in respect of the supply of gasoline. ...

CRA commented: A determination of the LP’s primary purpose would generally reflect its main or fundamental purpose at the time it was established – and may be reassessed later on. The … primary purpose [would not] be affected solely by short-term changes in the value of investments due to market shifts. In addition, the … statement … is not in itself sufficient to exclude the LP from being an ILP. ...

Calculation of Corporation X's qualifying revenue for the current reference period: Qualifying revenue (QR) calculation in relation to Corporation Y: $100 x $400 (QR attributable to Corporation Y)/$1,400 (Corporation X's total QR from non-arm's-length persons or partnerships) x $1,000(Corporation Y QR for current reference period)/$1,500 (Corporation Y QR for prior reference period) = 19 QR calculation in relation to Corporation Z: $100 x $1,000 (QR attributable to Corporation Z)/$1,400 (Corporation X's total QR from non-arm's-length persons or partnerships) x $1,300(Corporation Z's QR for current reference period)/$2,000 (Corporation Z's QR for prior reference period) = 46 The weighted average qualifying revenue for Corporation X for the current reference period is $65 ($19+$46). ... Calculation of Canco’s qualifying revenue for the current reference period: Qualifying revenue (QR) calculation in relation to Forco: $100 x $900 (QR attributable to Forco)/$900 (Canco total QR from non-arm’s-length persons or partnerships) x $1,500 (Forco QR for current reference period)/$2,000 (Forco QR for prior reference period) = 75 Since the prior reference period’s qualifying revenue is deemed to be $100, Canco has experienced the required reduction in revenue of at least 15% for the claim period. ... Meaning of “substantially all” Generally, the phrase “all or substantially all” means at least 90%. … However, the “all or substantially all” test could, depending on the circumstances and context, be satisfied even if the 90% level is not strictly achieved. ­­­­­­­­­­­­­­­­ ...