30 April 2018 Comfort Letter — Foreign spin-off – prescribed distribution
Miscellaneous administrative policy
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Folio Summary
S3-F10-C2 - Prohibited Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs -- summary under Subsection 207.06(2)
S3-F10-C2- Prohibited Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Subsection 207.06(2) Summary Under Tax Topics- Income Tax Act- Section 207.06- Subsection 207.06(2) Factors relevant to waiver of tax 2.36 Subsection 207.06(2) gives the Minister the authority to waive or cancel all or part of the 50% tax on prohibited investments or the 100% advantage tax in appropriate circumstances. ...
25 June 2015- 10:41am GMAC Leaseco – Tax Court of Canada finds that an amount received subject to future adjustment was unearned – but, by the same token, it was not “received” for s. 12(1)(x) purposes Email this Content GMAC received "support payments" from GMC in order to inflate the residual values stated in its leases of cars to GMC customers, thereby reducing the lease payments but resulting in a likely loss on lease termination. ... The Queen, 2015 TCC 146 under s. 9 – timing, s. 12(1)(x), s. 9 – compensation payments, s. 9 – computation of profit, s. 18(1)(a) – timing. ...
Miscellaneous severed letter
7 October 1990 Income Tax Severed Letter - Technical amendments — draft legislation on July 13, 1990 — Clause 31(8) — trusts
7 October 1990 Income Tax Severed Letter- Technical amendments — draft legislation on July 13, 1990 — Clause 31(8) — trusts Unedited CRA Tags none Dear Sirs: Re: Clause 31(8) Technical Amendments- Income Tax Act Draft Legislation- July 13, 1990 This is in reply to your letter dated July 19, 1990 wherein you requested our confirmation of your understanding on the above subject matter in a situation where an arriving immigrant sets up a non- resident discretionary trust and funds the trust with a loan. ...
Current CRA website
Farming Income and the AgriStability and AgriInvest Programs Guide – 2021 – Chapter 5 – Eligible capital expenditures
Farming Income and the AgriStability and AgriInvest Programs Guide – 2021 – Chapter 5 – Eligible capital expenditures On this page… Find out what an eligible capital expenditure is Find out what an annual allowance is Find out what a cumulative eligible capital account is Transitional rules – Undepreciated capital cost balance Transitional rules – Deemed gain immediately before January 1, 2017 Transitional rules – Dispositions of former ECP Transitional rules – Non-arm's length dispositions of former ECP As of January 1, 2017, the eligible capital property (ECP) system was replaced with the new capital cost allowance (CCA) Class 14.1 with transitional rules. ... Transitional rules – Deemed gain immediately before January 1, 2017 You may be able to include an amount in your income in a tax year that straddles January 1, 2017. ... Transitional rules – Dispositions of former ECP Receipts related to expenditures incurred before January 1, 2017, cannot result in excess recapture when applied to reduce the balance of the new CCA class. ...
News of Note post
10 April 2021- 11:41pm CRA is now applying a “proportionate attribution approach” in applying the EIA s. 5(2)(b) test of “control … of … voting shares” Email this Content S. 5(2)(b) of the Employment Insurance Act provides that “Insurable employment does not include … the employment of a person by a corporation if the person controls more than 40% of the voting shares of the corporation.” ... In stating that it accepted Boifor, so that its previous position was reversed, CRA addressed the example of two 50-50 (or 51-49) shareholders of a Holdco wholly owning their employer (Opco), and stated: In light of the FCA's decision, the CRA must now consider the proportionate attribution approach in similar situations to determine whether the employment of a person who controls more than 40% of the voting shares of the employing corporation is insurable. … … The proportionate attribution approach leads to the conclusion that the two shareholders each control more than 40% of Opco's voting shares (50% of 100%) for the purposes of EIA paragraph 5(2)(b). … … [W]here the shareholders held 51% and 49% of the voting shares of Holdco … their employment [also] would not be insurable because they had effective control of 51% and 49% of the voting shares of Opco …. ...
GST/HST Interpretation
20 December 2011 GST/HST Interpretation 122310 - GST/HST Interpretation - Production Proxy to be used by the [...] [Division] of [...] [Company X], and possible refund for the provincial portion of the HST for [...] repair parts
Through an agreement with [...] [Company Y], [Company X] provides [...], tools, appliances, equipment, supplies and other accessories, as well as the services and facilities necessary to carry out [...] [A] of [...] [B]. The [A] of [B] under the agreement is significantly larger in scope than a mere repair [...]. In [yyyy-yyyy], [Company X's] gross revenues were $[...] for the services that it provides, and $[...] for the [...] ...
Current CRA website
T4032-MB-July Payroll Deductions Tables – CPP, EI, and income tax deductions – Manitoba – Effective July 2025
T4032-MB-July Payroll Deductions Tables – CPP, EI, and income tax deductions – Manitoba – Effective July 2025 Notice to the reader Publication T4032, Payroll Deductions Tables, is available in sections for each province and territory. ... Please note that you can also use the Payroll Deductions Online Calculator (PDOC) to quickly calculate federal and provincial payroll deductions Section A t4032mb-july-general-information.html [HTML] t4032-mb-7-25e.pdf [PDF] Section B(i)- Canada Pension Plan contributions tables 52 pay periods a year (Weekly) [PDF] 26 pay periods a year (Biweekly) [PDF] 24 pay periods a year (Semi-monthly) [PDF] 12 pay periods a year (Monthly) [PDF] Section B(ii) – Second additional CPP contributions table When the province or territory of employment is other than the province of Quebec [PDF] Section C- Employment Insurance premiums tables When the province or territory of employment is other than the province of Quebec [PDF] Sections D and E- Federal and Manitoba provincial tax deductions tables 52 pay periods a year (Weekly) [PDF] 26 pay periods a year (Biweekly) [PDF] 24 pay periods a year (Semi-monthly) [PDF] 12 pay periods a year (Monthly) [PDF] Last update: 2025-06-27 Related document: T4032 Payroll Deductions Tables Thank you for your feedback Page details Date modified: 2025-06-27 ...
News of Note post
7 August 2017- 12:52am Halsall v Champion Consulting – High Court of England and Wales finds that knowledge that advice – that investing in a tax shelter was a “no brainer”- was negligent, commenced when HMRC started investigating Email this Content Investors in a UK charitable gift tax shelter subscribed for shares of a shell company and then, a short number of days later after the shell company had been listed on the AIM, donated their shares to a charity and claimed tax reductions on the basis that the shares had appreciated in value by four times. ... Summary of Halsall & Ors v Champion Consulting Ltd & Ors [2017] EWHC 1079 (QBD) under General Concepts – Negligence. ...
GST/HST Ruling
17 January 2013 GST/HST Ruling 130479 - […] – Place of supply [in a Province] – [Intangible Personal Property and Services]
The [Organization] is the national […] for […]. The [Organization] is registered for GST/HST purposes. 2. The [Organization] was incorporated to pursue the following objectives: […] 3. […] 4. ... The [Organization] sponsors […] conferences held in various locations in Canada. […]. ...