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GST/HST Interpretation
22 December 2020 GST/HST Interpretation 209955 - – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […]
22 December 2020 GST/HST Interpretation 209955- – Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […] Unedited CRA Tags Public Service Body Rebate (GST/HST) Regulations- Section 2 Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. Excise and GST/HST Rulings Directorate Legislative Policy and Regulatory Affairs Branch 10-320 Queen Street, Tower A Ottawa, ON K1R 5A3 [Addressee] Case Number: 209955 [Dear Client] Subject: [GST/HST Interpretation] [Public Service Body Rebate – Whether subsidies under certain programs are considered government funding] […] We are writing in response to your [correspondence] of May 25, 2020, wherein you request that we rule on whether the […][Canada Emergency Wage Subsidy (“CEWS”)] and […][10% Temporary Wage Subsidy for Employers (“TWS”)] programs are considered government funding for purposes of the Public Service Bodies’ (“PSB”) Rebate. ... For additional information on the CEWS program, see the Canada.ca webpage frequently asked questions – Canada emergency wage subsidy (CEWS). 3. ...
Archived CRA website
ARCHIVED - 5013-G – General Guide for Non-Residents – 2007 – General Information
Basic personal amount (line 300) – The amount has increased to $9,600. ... Just follow the symbol that applies to you… = deemed residents of Canada = non-residents of Canada = non-residents of Canada electing under section 217 of the Income Tax Act Is this tax package for you? ... Previous page | Table of contents | Next page Date modified: 2008-01-03 ...
Ministerial Letter
8 November 1989 Ministerial Letter 73828 F - Integrated Sawmill & Pulpmill - M & P Deduction
8 November 1989 Ministerial Letter 73828 F- Integrated Sawmill & Pulpmill- M & P Deduction Unedited CRA Tags 5202, 125.1(1) November 8, 1989 Carole Gouin-Toussaint Rulings Directorate Director Frank Gillman Bilingual Services & Resource Industries Division 7-3828 The Special Audits Division has requested that we withdraw one of our previous opinions which states that the "transportation activity of woodchips between the sawmill and the pulpmill which occurs within an integrated operation, be included as a qualified activity within the meaning of section 5202 of the Regulations so that the capital and labour costs of transporting the chips be included in the calculation of the M & P deduction. ... (ii) receiving and storing of raw materials, (iii) handling of goods in process... (b) all other activities... directly in connection with manufacturing or processing... but does not include any of (d) ... shipping... of finished goods, (e) purchasing of raw materials... ...
SCC
Montreal Coke and Manufacturing Co. v. Minister of National Revenue / Montreal Light, Heat & Power Consolidated v. The Minister of National Revenue, [1942] SCR 89
Minister of National Revenue / Montreal Light, Heat & Power Consolidated v. ... The particulars of the disbursements made by the Company in connection with this operation were as follows: (i) Interest on new bonds from September 16, 1935, to December 31, 1935, until when interest had to be paid on both the old and new bonds $ 23,207 54 (ii) Various expenses on retiring the old bonds and issuing the new bonds 12,484 92 (iii) Discount on issue of new bonds 28,000 00 (iv) Premium paid upon retirement of issue of old bonds 69,140 00 (v) Exchange premium paid on retirement of old bonds 36,744 81 $169,577 27 The first two items of expenses mentioned above were charged directly against the earnings for 1935. ...
Article Summary
Joel A. Nitikman, "Rectification: Specific Intent? General Intent? What is the Test? – Part II", Tax Topics, Wolters Kluwer, No. 2274, October 8, 2015, p.1. -- summary under Rectification & Rescission
– Part II", Tax Topics, Wolters Kluwer, No. 2274, October 8, 2015, p.1.-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission Test is one simply of true intention, not specific intent (pp. 3-4) In Juliar,…[t]he key passages from the Court of Appeal are these:… [I]t is possible,, even probable, that no one mentioned income tax throughout the nine or 10 months in issue. ... If there is no requirement for due diligence, it means that rectification is available even when there is a mistake — even a negligent mistake [f.n. 10. ... Coutts & Co, [2006] EWHC 1502 (Ch.) at paragraph 11, the Courts granted rectification even though the mistake was caused clearly by a professional advisor's negligence. ...
Article Summary
PWC, "Tax Insights: Investment limited partnerships ─ GST/HST & QST filing obligations", Issue 2020-27, May 04, 2020 -- summary under Investment Limited Partnership
PWC, "Tax Insights: Investment limited partnerships ─ GST/HST & QST filing obligations", Issue 2020-27, May 04, 2020-- summary under Investment Limited Partnership Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Investment Limited Partnership Meaning of “principal activity” A person’s “principal activity,” as discussed … in College of Applied Arts … depends on how important a particular activity assists the person in achieving its overall business objectives and goals when compared to its other business activities. ...
Article Summary
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission -- summary under Paragraph (b)
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission-- summary under Paragraph (b) Summary Under Tax Topics- Income Tax Act- Section 183.3- Subsection 183.3(1)- Reorganization- Paragraph (b) Vertical amalgamations It is common for an “Acquisitionco” to acquire all the shares of a public company target (“Targetco”), whose shares are not delisted until after a delay, and to vertically amalgamate with it. ... (b) of the definition, the equity holders of the covered entity (Acquisitionco as the holder of Targetco shares) must receive equity of Amalco – and such equity is instead cancelled for no consideration. ...
Article Summary
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission -- summary under Subsection 183.3(2)
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission-- summary under Subsection 183.3(2) Summary Under Tax Topics- Income Tax Act- Section 183.3- Subsection 183.3(2) Potential duplication under s. 183.3(2) Under a literal reading of s. 183.3(2), every covered entity would have an amount under Variable B when equity of any other covered entity is redeemed, acquired or cancelled pursuant to a reorganization transaction (and a portion of the consideration is not equity). ...
Article Summary
Roderick I’Anson Banks, "Lindley & Banks on Partnership", (Sweet & Maxwell, 20th Ed.) 2017 -- summary under Section 96
Roderick I’Anson Banks, "Lindley & Banks on Partnership", (Sweet & Maxwell, 20th Ed.) 2017-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 Distinction between employee and partner/fixed distribution entitlement (5-20) [I]gnoring for the present section 2(3)(b) [the same as Partnerships Act (Ont.), s.3.3(b)], it was frequently held prior to the 1890 Act that employees who were remunerated by reference to the profits of a business were not partners therein, at least where it appeared from the agreement that no partnership was intended. ... & C. 867; Ex p. Chuck (1832) 8 Bing. 469; Gilpin v. Enderby (1824) 5 B. & A. 954. In such a case, an express term in the agreement negativing any implication of partnership may be ineffective vis-a-vis third parties, such as HMRC: see Fenston v. ...
Article Summary
Mark Woltersdorf, "Restrictive Covenants – The Final Chapter (For Now) – Part II", CCH Tax Topics, No. 2135, 7 February 2013, p. 1 at p. 4: -- summary under Subsection 56.4(6)
Mark Woltersdorf, "Restrictive Covenants – The Final Chapter (For Now) – Part II", CCH Tax Topics, No. 2135, 7 February 2013, p. 1 at p. 4:-- summary under Subsection 56.4(6) Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(6) Paragraphs 56.4(6)(e) (arm's length employee exception) and 56.4(7)(d) ("goodwill amount" and "disposition of property" exceptions) provide that no proceeds can be received or receivable by the individual granting the RC. ...