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Thus, the issue would turn on whether there was substantial renovation of the physical space for each proposed condo unit – with CRA reiterating in this regard its longstanding position that to rise to the level of substantial renovation there would need to be a gutting (or more) of each unit at issue. ...

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). ...

V, Pt. 1, s. 6 or 6.1, the portions of the upfront payments that were “attributable” to such lease intervals would be exempted – whereas the portion of the upfront payment attributable to any subsequent lease intervals where the use became taxable would be subject to GST/HST. ...

GST/HST Info Sheet GI-200 Application of the GST/HST to Credit Card Surcharges March 2023-- summary under Paragraph (i) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service- Paragraph (i) Description of credit card surcharge What is a credit card surcharge [A] credit card surcharge is a fee that …: it is charged to the cardholder solely for the acceptance of the use of the credit card as a payment method and is not charged if another payment method is used it is imposed by the merchant who provides, to the cardholder, the property or service that is purchased with the use of the credit card [and] it is subject to the relevant payment card network rules relating to surcharging, including rules regarding the calculation and level of the fee Exemption under para. ...

Accordingly, there was no question of introducing an economic substance component – rather, it was a question of how to do so while not at the same time upending the GAAR rule and throwing out 30 years of caselaw. ...

. … Consequently, the Canada Revenue Agency will waive the application of penalties and interest for any late-filed UHT returns and for any late-paid UHT payable for the 2022 calendar year, provided the return is filed and the UHT is paid by April 30, 2024. ...

. … Ability to redeem and frequency of redemptions An investment fund provides investors with an ability to redeem with reference to net asset value (NAV). ...

CRA Webpage, “Loans and Employee Debt” 14 November 2023-- summary under Subsection 80.4(1) Summary Under Tax Topics- Income Tax Act- Section 80.4- Subsection 80.4(1) relief from imputed interest on small short-term loans made to employees … Non-taxable situation If the loan is received or a debt is incurred because of employment, the interest benefit is not taxable if all of the following apply: Total amount of all loans received is $10,000 or less per calendar year (includes loans of different term durations and principal amounts) Term of the loan(s) is 60 days or less Loan is not received because of shareholdings [i.e., the person or partnership is a shareholder of a corporation, connected with a shareholder of a corporation or a member of a partnership or beneficiary of a trust that was a shareholder of a corporation, and because of such shareholdings, the person or partnership receives a loan from, or incurs a debt to the corporation, a corporation related to that corporation or a partnership of which the corporation or the related corporation was a member] If the term of the loan spans 2 calendar years, the loan will count as part of the $10,000 limit for the year in which the loan was received. ...

If the corporation does not have reasonable knowledge of where the property is being used, or the corporation does not have a permanent establishment in the jurisdiction described in … (a), the gross revenue should be allocated to the permanent establishment to which the person negotiating the lease may reasonably be regarded as being attached. 2.54 Regarding reasonable knowledge, the corporation may have knowledge of the location where the leased property is being used simply by virtue of the relationship with the client. ...

. … [I]t is the longstanding administrative practice of the CCRA that a subsection 15(1) benefit will not be assessed in respect of a benefit arising from the reinvestment of dividends in additional shares under a DRIP, provided that the amount paid for the additional shares is not less than 95% of their fair market value. ...