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Before concluding that it would “generally consider emergency government assistance, including assistance from provinces and municipalities, directly related to COVID-19 to be an extraordinary item,” but that this would include “COVID-19-related government assistance … to the extent that it replaces or is meant to replace normal or recurring government assistance,” the Directorate stated: Generally, we would expect extraordinary items to meet all three of the following characteristics: a) Not be expected to occur regularly or frequently within several years Grants or other government assistance that an entity is eligible to receive on a regular or reoccurring basis would not meet this criteria. b) Not typical of the normal activities or risks inherent in the normal operations of the entity Consideration should be given to the nature of the services or products offered by an entity and the normal environment in which it operates. c) Primarily out of the control of owners or management Consideration should be given to the extent that inflows are influenced by the decision of owners or management. ...

If the RSUs are settled in Year Four, more than three years after the end of the year in which these services were rendered, the paragraph (k) exception would not apply …. ...

The reason is that (a)(ii) of the ERDTOH definition only adds the Part IV tax if it generated a dividend refund to the connected payor out of its ERDTOH – and since the connected payor by assumption had not yet transitioned to the ERDTOH/NERDTOH regime, this would not be possible. ...

“[I]t is not necessarily the case that a qualifying property of an eligible entity will always conform to its legal title” – for example, the leasehold interest of a commercial tenant may represent only a portion of the legal title of the property. ...

Accordingly … business interruption insurance proceeds would generally be included in qualifying revenue and would generally not be considered an extraordinary item. ...

After indicating that where a taxation year has already been assessed on the basis of a fiscal period end, the Act does not have any provision that allows a reassessment to change the FPE, the Directorate went on to state: [T]he … [preamble] wording of subsection 249.1(1) indicates that the purpose of specifying a particular period of time as a fiscal period is that a corporation can choose, within the parameters specified under the subsection, a FPE for preparing its accounts for the purposes of assessment. ...

CRA stated, regarding the requirement that there have been a written agreement entered into before October 9. 2020: [W]hile there is no requirement that the documents be signed … the written documents must show a clear intention to create a binding and enforceable contractual relation, outline all the essential terms and conditions of the agreement, and demonstrate an acceptance in writing by both parties of the terms and conditions. ...

CRA stated that this was “possible … assuming that the Lease includes the same enforceable and binding rights and obligations, and terms and conditions, as the [letter agreement].” ...

…[T]here are other factors that may affect [this] determination …. For example, the sublease itself may contain a condition stipulating that the agreement would not take effect until the signature of the landlord was procured. ...

CRA stated: … [I]t appears that the requirements to use the rule in paragraph 125.7(4)(d) could be met since all of Opco’s revenue would be considered to be derived from persons with which Opco does not deal at arm’s length (the participants of the joint venture, Holdco 1 and Holdco 2). ...