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. … As defined in section 3 of the Assisted Human Reproduction Act, an in vitro embryo means an embryo that exists outside the body of a human being. Treatment of the subject supplies before amendments passed [C]linics and donor banks are not liable to pay GST on the importation of in vitro embryos after March 19, 2019. … However, consistent with its standard practice, the Canada Border Services Agency is administering this measure on the basis of the proposed amendment. ...

For example, respecting element A: As an amount paid in error as or on account of tax is not tax, the amount should not be included in Element A of the SAM formula which includes all tax … that became payable under any of subsection 165(1) and sections 212, 218 and 218.01 by the financial institution during the particular reporting period or that was paid by the financial institution during the particular reporting period without having become payable. … CRA concluded: Consequently, if an SLFI has included an amount in Element A and Element F of the SAM formula in a particular reporting period and subsequently it is determined that the amount was paid in error by the SLFI as or on account of tax, as the amount is not tax payable under subsections 165(1), 165(2) or sections 212, 212.1, 218 or 218.01, the SLFI’s SAM formula calculation should be corrected to remove the amount from Element A and Element F for the reporting period in which that amount was included. ...

Private meetings are excluded …. Fast food chain could supply the school cafeteria lunches 5. ... The exemption under section 12 … applies to the supplies of such lunches, provided that the supplies are made primarily to students in a location determined to be a school cafeteria. ...

Canada Revenue Agency increases flat rate amount for meal claims, and reasonable amount for meal benefits and allowances 3 September 2020 CRA Press Release-- summary under Subparagraph 6(1)(b)(vii) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii) Increase in presumptively reasonable overtime or travel meal allowance from $17 to $23 CRA … has increased the amount that employers can use to determine whether an overtime meal or allowance, or the meal portion of a travel allowance is taxable, from $17 to $23. ... These increases are effective immediately and retroactive to January 1, 2020. … CRA policy re exclusion of reasonable overtime or travel meal allowance The CRA’s policies on taxable benefits and allowances allows an employer to exclude the value of an overtime meal or allowance, or certain travel allowances (including a meal portion), from an employee’s income as long as the value is reasonable (amongst other conditions). ...

LLC, but there were back-to-back agreements between USco and LLC, and between LLC and Canco under which LLC had committed under a forward subscription agreement with Canco to fund the interest payments under the loan, and USco had committed to make matching capital contributions to LLC – with CRA indicating that it had “resolved” this file “on the basis that paragraphs 247(2)(b) and (d) … and transfer pricing penalties applied.” ...

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). ... (a) nor (b) of the definition- nor is it under (d)(ii) since the former part of the residential complex was previously occupied – so that s. 195.1(1) could not apply to prevent the application of the s. 206 rules. ...

If on an examination or audit, CRA determined that an NHR claim was filed in error, and an amount would become payable as a result of the NHR denial, CRA would consider the claimant’s eligibility for an NRRPR and if the claimant was determined to be eligible, the NRRPR amount would be offset against any amount owing from the NHR denial – even if the examination or audit continued beyond the relevant two year rebate filing time limit. ... The claimant may send their request in writing to the same tax centre they sent their original application …. ...

Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025-- summary under Paragraph 214(3)(a) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(3)- Paragraph 214(3)(a) Deferred imposition of Part XIII tax 1.90 … If there is no series of loans or other transactions and repayments, the non-resident who has received a loan in a particular taxation year cannot be deemed to have received a dividend until one year after the end of the lender's tax year. ... If the tax is not remitted by this day, interest will start accruing as of the 16th day of the month following the end of the lender's tax year. 1.92 If a PLOI election is available in respect of a loan but has not yet been filed, the CRA will assess Part XIII withholding tax after the time period described in subsection 15(2.6) has elapsed. … Assignment of loan before repayment 1.97 In a situation where a loan amount that is owed by a non-resident borrower has been assigned by the original lender to a new lender and the borrower subsequently repays the loan to the new lender, the borrower may still be entitled to a refund of the Part XIII tax previously assessed. ...

. … [T]he payment of a fee by the subsidiary with respect to th[e] guarantee might taint the trust. In … 2004-006822, the CRA was satisfied that the guarantee described therein would not disqualify the mutual fund trust under subparagraph 132(6)(b)(i), even though it was provided to a corporation which was not wholly owned by the trust because the particular facts indicated that the guarantee formed part of the core investment undertaking of the trust. ...

. … Exceptions to the direct use test- borrowed money used by a partnership to return capital to a partner 24. The concepts described in ¶ 23 are equally applicable where a partnership borrows money to return capital to a partner. ...