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23 January 2023 External T.I. 2020-0865161E5 F- SSUC/CEWS – Sous-alinéa 125.7(4)e)(i) et personne-- summary under Paragraph 125.7(4)(e) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(4)- Paragraph 125.7(4)(e) electing taxpayer can receive amounts through third party where receipt on its behalf is established by agreement or statute Regarding the time at which an amount is regarded as received by an eligible entity which has made an election under s. 125.7(4)(e)(i) to use the cash method in determining its qualifying revenues for CEWS purposes, where the amount is received by a third party before being paid to the eligible entity, CRA stated: IT-433R … states [in subpara. 3(a)] that the meaning of the term "received" is broad enough to consider a taxpayer to have received an amount at the time that inter alia it was received by a person authorized to receive it on behalf of the taxpayer. … [A] person entitled to receive an amount on behalf of a taxpayer for CEWS purposes may include a person who is entitled to receive the amount for a taxpayer by inter alia an agreement or by statute. ...

3 December 2024 CTF Roundtable Q. 11, 2024-1038241C6- Global Minimum Tax Act – Interpretation and Application of OECD Agreed Administrative Guidance-- summary under Subsection 3(1) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Global Minimum Tax Act- Section 3- Subsection 3(1) CRA will consult with Finance re potential amendments to catch up to OECD guidance in administering the GMTA How will the Global Minimum Tax Act (GMTA) be administered in circumstances where its enacted state does not reflect changes to the GloBE Model Rules, or to new GloBE Commentary or Administrative Guidance? CRA indicated that, to apply the GMTA as intended, as new administrative guidance is released, the DST and Global Tax Section of CRA will consult with the Department of Finance to determine, on a case-by-case basis, how such guidance should be handled – whether there is a potential legislative amendment or whether CRA will apply the new guidance to inform its interpretation of the GMTA. ... Therefore, CRA will administer the provisions of the GMTA to achieve what the administrative guidance clarifies should be the outcome – that is, the constituent entity covered taxes paid by the upper-tier entity being pushed down to the constituent entity. ...

18 November 2004 Internal T.I. 2004-0083251I7- Management Fees-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission General discussion of the distinction between rectification of mistakes and retroactive tax planning. ...

28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt A taxpayer is not considered to have "paid" interest on a loan owing by him to a charitable foundation by virtue only of journal entries being recorded in his ledgers and those of the foundation. ...

15 June 1992 T.I. 921368 (December 1992 Access Letter, p. 18, ¶C56-208)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt No payment will be considered to occur pursuant to an agreement between the parties to the effect that interest on a promissory note will be deemed to be paid and then loaned back to the borrower. ...

"Patronage Dividends Paid by Non Co-ops")-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Payment of a patronage dividend may be effected by the issuance of shares or debt instruments, where such an arrangement is authorized by the customer. ...

(Tax Window, No. 24, p. 8, ¶2184)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt A direct payment by a non-resident to Revenue Canada of a tax liability of a related Canadian corporation would entail the receipt of an amount by the Canadian corporation for purposes of s. 12(1)(x). ...

7 August 1992 T.I. 921752 (May 1993 Access Letter, p. 198, ¶C76-066)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Because the function of a journal entry is to record a transaction rather than to make it legally effective, the reclassification of a shareholder's loan into remuneration payable by a journal entry would not be considered to be payment of the remuneration. ...

10 October 2014 APFF Roundtable Q. 6, 2014-0538251C6 F- 2014 APFF Roundtable, Q. 6- Application of subsection 75(2) after Sommerer-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission no comment on Pallen Trust CRA declined to comment on Pallen Trust, 2014 BCSC 305, as it had been appealed to the British Columbia Court of Appeal. ...

18 February 1999 External T.I. 9825635- VALIDITY OF 104(5.3) ELECTION-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission The comments in IT-378R, that the validity of an election may not be denied by a taxpayer once it is accepted by the Department, is applicable to other elections. ...