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CRA indicated that the loss carryback requested on the form T3A filed with the 2 nd return will not be processed concurrently with the T3 return for 1 st taxation year, as the loss must first be recognized by CRA before it can be applied to the earlier taxation year – so that the initial notice of assessment for the 1 st taxation year would not reflect the carryback, and would show interest owing where the computed balance of tax owing was not paid on or before March 31. ...

These are additions to our set of 1,331 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 11 ¼ years of releases of Interpretations by the Directorate. ...

Additional summaries of Frequently asked questions- Canada emergency wage subsidy (CEWS) CRA Webpage 21 December 2020 under s. 125.7(4)(b), 125.7(1) – baseline remuneration, eligible remuneration, s. 125.7(4)(d) and s. 241(3.5). ...

Summaries of 13 November 2020 Internal T.I. 2020-0864831I7 under s. 248(1) – SDA, s. 7(3)(b) and s. 15(1). ...

CRA has now imposed a condition, effective March 16, 2021, that prohibits employers and members from contributing to a money purchase provision of an IPP or to a designated plan if actuarial surplus under the defined benefit provision of the plan is more than the surplus limit – so that any required contributions to the plan’s money purchase provision are permitted only if they are made from the surplus. ...

., a “right under a contract … to control the voting rights attached to the share.” ...

Did the stipulation in s. 90(9)(b), that the CFA exempt surplus must be “not relevant in applying this subsection in respect of... any deduction under subsection... 113(1) in respect of a dividend paid, during the period in which the particular loan … is outstanding” signify that Canco could not access the s. 90(9) deductions in years 1 to 3, because the loan was still outstanding in year 4 at the time that the dividend was paid out of exempt surplus? ...

What likely would come within s. 3(e)(i) is something like a conventional mutual fund which has already gone through the hoops so as to be qualified to be in continuous distribution – as contrasted, at the other extreme, to a conventional ILP which if it, for example, has no intention of preparing a current offering memorandum, is not yet qualified to distribute securities, even on a private placement basis. ...

Although the effect of loss of the SBD is to reduce the tax deferral benefit of corporate earning of the active business income (ABI), Ontario and New Brunswick did not adopt a matching AAII rule – so that in Ontario, for example, a CCPC earning ABI of $500,000 and AAII of $150,000 can still obtain a tax-deferral benefit at the Ontario level of up to $41,500 annually. ...

Summary of 2021 Ruling 2020-0858321R3 under s. 248(1) – SDA. ...