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Situation D-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A Revenues 4.9:1 1.6:1 13.5:1 0.5:1 Assets 5.6:1 1.1:1 21.0:1 0.5:1 # of Employees 4.0:1 1.6:1 38.8:1 0.1:1 To date… Rulings has not denied the availability of treaty benefits under Article XXIX-A(3) on the determination that the US business was not substantial in comparison to the Canadian activities. ...

IC 72-17R6 "Procedures concerning the disposition of taxable Canadian property by non-residents of Canada- Section 116"-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition "... ...

. … It is expected that the CRA will announce formal changes to the program in the fall of 2017. ...

Canada Emergency Wage Subsidy (CEWS) Calculator under Who is an eligible employer, 21 April 2020 CRA Webpage-- summary under Qualifying Revenue Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Qualifying Revenue What is an eligible revenue reduction … Use your normal accounting method when calculating revenue. ...

Canada Emergency Wage Subsidy (CEWS) Calculator under How to apply, 21 April 2020 CRA Webpage-- summary under Subsection 125.7(6) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(6) Incorrect or fraudulent claims … If you artificially reduce your revenue for the purpose of claiming the wage subsidy you will be required to repay any subsidy amounts you received plus a penalty equal to 25% of the total value. ...

. … With respect to any particular program, a degree of basic care and supervision is normally provided although the program may also involve activities and instruction which enrich the program. ... The supply to the parents of each child is a separate supply. … The supply of child care services to the parents of the 15-year old is not exempt …. ...

The Queen, it is the position of our Directorate that a flexible approach to tracing funds is to be used in the context of the application of subsection 84(2). […] It should be noted that the Federal Court of Appeal in MacDonald did not consider the brother-in-law to be an accommodation party to the transaction, as in RMM, in concluding that s. 84(2) applied. ... As stated in MacDonald [at para. 27, quoting RMM], the " words ‘distributed or otherwise appropriated in any manner whatever on the winding-up, discontinuance or reorganization of its business’ are words of the widest import, and cover a large variety of ways in which corporate funds can end up in a shareholder’s hands.” ... This was a well-considered scheme adopted on the advice of professional advisers after other means of extraction of the undistributed income (…) However, it is the CRA's view that the strict and literal approach to the interpretation of subsection 84(2) adopted by the Federal Court of Appeal in Vaillancourt-Tremblay has clearly been rejected by that same court in MacDonald. ...

Income Tax Technical News No. 19, 16 June 2000-- summary under Paragraph 110(1)(d) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110- Subsection 110(1)- Paragraph 110(1)(d) "... ...

IT-291R3 "Transfer of Property to a Corporation under Subsection 85(1)"-- summary under Paragraph 85(1)(b) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(b) allocation of assumed debt amongst transferred properties 17 … Paragraph 85(1)(b), however, will not apply where the fair market value of the non-share consideration given (including the assumption of debt by the transferee) is allocated among several properties transferred and retained by the transferee and the amount allocated to each asset is not greater than the agreed amount in respect of each asset. ...

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