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It stated: [T]he Notice of Intent … is a compliance tool to be used at the disposal of the CRA; it is not taxpayer-initiated. ...

Accordingly, there was no question of whether or not to introduce 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. ...

Summary of 7 April 2022 CBA Roundtable, Q.15 under ETA s. 217 – imported taxable supply. ...

After noting that the benefit from rent-free use of the property would generate Part XIII tax under ss. 15(1), 15(1.4)(c) and 214(3)(a), CRA indicated that, where the fair market rent did not provide a reasonable return on the value of the property, the amount of the benefit was to be determined using the imputed rent approach – which in general entailed multiplying a normal rate of return for the non-resident corporation by the greater of the cost and fair market value of the property, and adding operating costs other than interest paid on liabilities connected with the property. ...

Summary of 2021 Ruling 2020-0865991R3 under s. 212(3) – participating debt interest. ...

II, s. 13(c) indicated that the services of the Service Provider were exempted if they were provided by it in in addition to home care services rendered by a government-funded supplier – a requirement which was argued to be satisfied by the services of the Centre to X. ...

., it charged an agreed price for each licence to the representative, who established the price at which the licence would be sold to the end-user – and it was the representative who invoiced the end user and was responsible for collecting the invoice. ...

Although this by itself would not have much impact (Canada’s tax treaties are interpreted in light of the OECD commentaries where relevant, without a specific provision to that effect), what is more significant is that these rules refer to the relevant OECD recommendations “as amended from time to time” – which raises the possibility of an interpretive expansions of the rules in the Act through OECD later-in-time materials. ...

17 August 2023- 11:37pm CRA indicates that s. 56(1)(r)(i) rather than s. 5(1) applies to inducement payments made by the government directly to a prospective hospital employee Email this Content CRA indicated that where a provincial government sponsors a program that is designed to deliver incentive payments or earnings supplements directly to eligible nurses, such amounts are included in their income under s. 56(1)(r)(i) (“earnings supplements provided under a [government-sponsored] project … to encourage individuals to obtain or keep employment”) whereas if it sponsors a program designed to have employers deliver the payments directly to them, such amounts are included in their employment income under s. 5(1). ...

After noting that the (apparently Quebec) statutory provisions governing an IMB are similar to those governing a CBCA corporation, including providing that the IMB is a legal person (“personne morale”), has limited liability, except in relation to certain borrowings, has a board of directors and is governed by by-laws and resolutions – and the interests in it carry voting rights, CRA concluded that such an IMB qualifies as a corporation. ...