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Consequently … A Co has a contingent right to be paid money from Drug Co. … A Co will make a supply of these same contingent rights to Finance Co. ...

As well, if the election is in effect, the following rules apply in respect of each residual input of the financial institution: the extent to which the residual input is acquired by the financial institution or is consumed or used for purposes other than making taxable supplies for consideration is deemed to be equal to the difference between 100% and the prescribed percentage for the prescribed class of financial institution (that difference being 88% for banks, 90% for insurers and 85% for securities dealers) for the purpose of determining an ITC in respect of the residual input, the description of B in the formula in subsection 169(1) is deemed to be equal to the prescribed percentage for the prescribed class of financial institution … 103. To make an election under subsection 141.02(9), use Form GST118 …. ...

These and related changes are reflected in the updated CRA Webpage on the “ Pertinent loans or indebtedness (PLOI) ”. ...

CRA responded: a) … Paragraph (a) of the definition of “residential complex” … includes that part of a building in which one or more residential units are located. ...

In finding that s. 190(1) would not apply, CRA noted that the s. 190(1) preamble requires that a person begins to hold or use real property as a residential complex – whereas here, the person (NewCo) held a single residential complex both before and after the transaction (merely expanding the size of its residential complex). ... (a) nor (b) of the definition- nor is it under (d)(ii) since the former part of the residential complex was previously occupied – so that s. 195.1(1) could not apply to prevent the application of the s. 206 rules. ...

If on an examination or audit, CRA determined that an NHR claim was filed in error, and an amount would become payable as a result of the NHR denial, CRA would consider the claimant’s eligibility for an NRRPR and if the claimant was determined to be eligible, the NRRPR amount would be offset against any amount owing from the NHR denial – even if the examination or audit continued beyond the relevant two year rebate filing time limit. ... The claimant may send their request in writing to the same tax centre they sent their original application …. ...

Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025-- summary under Paragraph 214(3)(a) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(3)- Paragraph 214(3)(a) Deferred imposition of Part XIII tax 1.90 … If there is no series of loans or other transactions and repayments, the non-resident who has received a loan in a particular taxation year cannot be deemed to have received a dividend until one year after the end of the lender's tax year. ... If the tax is not remitted by this day, interest will start accruing as of the 16th day of the month following the end of the lender's tax year. 1.92 If a PLOI election is available in respect of a loan but has not yet been filed, the CRA will assess Part XIII withholding tax after the time period described in subsection 15(2.6) has elapsed. … Assignment of loan before repayment 1.97 In a situation where a loan amount that is owed by a non-resident borrower has been assigned by the original lender to a new lender and the borrower subsequently repays the loan to the new lender, the borrower may still be entitled to a refund of the Part XIII tax previously assessed. ...

. … [T]he payment of a fee by the subsidiary with respect to th[e] guarantee might taint the trust. In … 2004-006822, the CRA was satisfied that the guarantee described therein would not disqualify the mutual fund trust under subparagraph 132(6)(b)(i), even though it was provided to a corporation which was not wholly owned by the trust because the particular facts indicated that the guarantee formed part of the core investment undertaking of the trust. ...

. … Exceptions to the direct use test- borrowed money used by a partnership to return capital to a partner 24. The concepts described in ¶ 23 are equally applicable where a partnership borrows money to return capital to a partner. ...

Does the first fact pattern in the Explanatory Notes under the heading "Example – Exchangeable Shares", involving a share of a Canco that is exchangeable by its terms for shares of a Forco, not constitute a "derivative forward agreement" because the exchange right embedded in the share is not an agreement? CRA responded: The DFA rules are… intended to address certain structures that have the effect of transforming income into capital gains. … The CRA cannot confirm that an exchange right embedded in a share is not an "agreement" for purposes of the DFA definition. ...