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The server plays a more limited role in cryptocurrency mining – solving algorithms. ... To be a permanent establishment the non-resident person must make supplies through that fixed place of business – meaning the activities carried out by the non-resident server must, on their own, be an essential and significant part of the business activity of the non-resident person as a whole. … The CRA currently has a couple of ruling requests that involve cryptocurrency mining, and is currently reviewing whether a non-resident miner with servers in Canada would be considered to have a permanent establishment in Canada by virtue of the mining activities that are carried on through those servers. ...

., less than 90%) in the registrant's commercial activities, CRA stated: Generally, subsection 202(4) … provides for an ITC (determined by the formula 'A x B') equal to the tax fraction (7/107) of the CCA in respect of the passenger vehicle or aircraft that was deducted under the Income Tax Act in computing the income of the registrant from those commercial activities for that taxation year of the registrant. … [A]lthough [s. 202(4)] does not require the registrant to segregate the class 10 vehicle from all other property in that class… it does, however, call for a separate calculation to be made by the registrant (formula 'A x B' discussed above) to determine the correct amount of ITC available on the passenger vehicle. It is therefore our opinion that a separate tracking system may be required …. ...

He noted that the August 9 GAAR consultation paper stated at its outset that Finance thinks the GAAR is working reasonably well – but, even so, it could do with a tune-up after more than 30 years of practice, experience, tax administration and case law. ... Although the paper sought to cover the possible proposals in a balanced manner, even being transparent where a possibility was perhaps not workable or necessary, some of the proposals still prompted strong reactions – all of which is an expected and useful part of the consultation process. ... Although the judicially developed analytical framework is reasonably sound, there are some cases that may benefit from a further statutory “nudge” with regard to economic substance – and the case was made in the paper for this benefiting the efficiency of the system overall. ...

. … Number Title T2224 Transitional Rules Election T2225 Group Ratio Rules Election under subsection 18.21(2), and Fair Value Adjustments Election under subsection 18.21(4) T2226 Election to Transfer Cumulative Unused Excess Capacity under Subsection 18.2(4) T2227 Excluded Interest Election Under Subsection 18.2(1) T2228 Specified Pre-regime Loss Election under subsection 18.2(1) T2229 Election to forgo a foreign accrual property loss under clause 95(2)(f.11)(ii)(E) … How to file the election before the forms are available If you need to file an election before the forms are available, you may send a letter containing the information required under the relevant election provision in the Income Tax Act with the signatures of all taxpayers or partnerships who are party to the election. … You will need to submit a separate letter for each election. ...

CRA indicated that: … [N]o information will be released to the police or other law enforcement agencies without the approval of the Assistant Commissioner of the Compliance Programs Branch. … Since enactment in June 2014, the CRA has not exercised its authority under the new legislation. ...

GST/HST Memorandum 17-11 [17.11] Determining Whether a Financial Institution is a Qualifying Institution for Purposes of Section 141.02 23 July 2021-- summary under Residual Input Tax Amount Summary Under Tax Topics- Excise Tax Act- Section 141.02- Subsection 141.02(1)- Residual Input Tax Amount SLFIs only account for federal tax in residual input tax amount 16 … [T]hese provisions [in para. ... (b)] include the federal, but not the provincial, part of the HST …. ...

. … If there is no transfer of ownership of a particular property, we do not consider a supplier to have sold, and a recipient to have purchased, the property. … Accordingly, property leased from a lessor is generally not considered to have been acquired for income tax purposes and, as such, is not treated as capital property for purposes of the ITA or, by extension, the ETA. ... Therefore, property leased from a third party will not be considered to be capital property for GST/HST purposes, regardless of whether the lessee and the lessor have made an election under subsection 16.1(1) …. ...

. … With respect to other adjustments for amounts that the vendor has paid or collected and that relate to the period during which time the purchaser will be the owner of the real property, it is a question of fact as to whether the adjustments increase or decrease the value of consideration for the sale of the real property. … [I]f an obligation is inextricably tied to the real property itself, then it is likely not a separate supply from the sale of the real property and the adjustment likely increases or decreases the value of consideration, as the case may be. Conversely, if it is determined that an obligation giving rise to the adjustment is a separate supply from the sale of the real property that is not incidental to the sale of the real property, then the application of the GST/HST to the adjustment depends on the nature of the separate supply itself. … With respect to any adjustment described above that is made post-closing (that is, made after the transaction has been finalized and the purchaser has paid the balance owing to the vendor), the application of the GST/HST to the adjustment would be as described above. ...

. … Where, under a stock option agreement, an employer elects to pay cash in lieu of issuing shares, subsection 7(1) does not apply and the amount of cash received by the employee is taxable under either subsection 5(1) or paragraph 6(1)(a)…. Where it is the employee who has the right to choose cash instead of shares, paragraph 7(1)(b) will apply, in respect of the cash received by the employee in satisfaction of the employee's rights under the plan. … ...

. … [W]here the CSA represents a type of an agency relationship or a mandate for the employers, each of the separate eligible employers may qualify for the wage subsidy in respect of their portion of eligible remuneration paid to each eligible employee by the agent or the mandatary in respect of a week in a claim period, as long as all of the other eligibility criteria have been met …. Only the actual employer(s) can apply for the wage subsidy in respect of a particular employee …. ... New: October 6, 2020 [The] case law, which generally describes a joint venture as a limited business undertaking by two or more parties, in which the parties have a joint property interest in the subject matter of the venture and share control and management of the enterprise. … A joint venture is not an eligible employer for the purposes of the wage subsidy. ...