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Modernizing and Strengthening the General Anti-Avoidance Rule, Department of Finance Consultation Paper, 11 August 2022-- summary under Subsection 245(3) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(3) Narrowing “bona fide purpose” It may be appropriate to provide that a “ bona fide purpose” does not include foreign (or provincial) tax savings (contrary to what was suggested obiter by the TCC in Loblaw), and perhaps the same should be done for creditor proofing (whose presence as a purpose may be “particularly difficult for the Crown to confirm or refute” (p. 12). ...

GST/HST Notice No. 324, Proposed Amendment Addressing Mining Activities in respect of Cryptoassets, February 2023-- summary under Subsection 188.2(4) Summary Under Tax Topics- Excise Tax Act- Section 188.2- Subsection 188.2(4) No GST collectible re mining activity (under “Collection of tax”) Subject to the exclusion in proposed subsection 188.2(5) … where a person receives money, property or a service as a fee, reward or payment, or any other form of remuneration, as a consequence of performing a mining activity, the provision of the mining activity is deemed not to be a supply for GST/HST purposes under proposed subsection 188.2(4). ...

Since C owns as trustee, C must file a return for the 2022 year – but does not have to pay tax for C’s 100% ownership interest because C owns the property solely as the trustee of a specified Canadian trust. ...

. … You must file an annual return with the Canada Revenue Agency (CRA) on or before April 30 for each residential property that you own on December 31 of the preceding calendar year. ...

CRA responded that s. 301(3) “allows an Appeals Officer to exercise their judgement to make an upward adjustment with respect to a matter under dispute, or a related matter within the same period under objection, where the matter is of relative importance, including being in relation to the FMV of a disputed property” – and also indicated that “[a]ny upward adjustment must be approved by the Appeals Officer’s manager or the Chief of Appeals.” ...

Underused Housing Tax Notice UHTN15, Questions and Answers About the Underused Housing Tax, 17 April 2023-- summary under Taxable Value Summary Under Tax Topics- Other Legislation/Constitution- Federal- Underused Housing Tax Act- Section 2- Taxable Value Assessed value used even where excess land (para. 2.1) Where, for example, the assessed value of a 10 hectare plot of land reflects the value of land (9.5 hectares) that is not necessary for the use of the house on the land as a residence, the taxable value of that property nonetheless is based on that assessed value, unless an election is made to use the FMV of the residential property (which generally would only include the ½ hectare). ...

. … Consequently, the Canada Revenue Agency will waive the application of penalties and interest for any late-filed UHT returns and for any late-paid UHT payable for the 2022 calendar year, provided the return is filed and the UHT is paid by April 30, 2024. ...

IV of the Regs. 2.22 … By virtue of section 16 of the Interpretation Act, this definition of gross revenue [in s. 248(1)] also applies for purposes of the Regulations. ...

When a corporation conducts all or part of its operations in partnership with one or more other persons, subsection 402(6) of the Regulations provides that for the purposes of subsection 402(3) … the corporation must include in its gross revenue for the tax year and in its salaries and wages paid in the tax year its proportionate share of the gross revenue of the partnership and the salaries and wages paid by the partnership. ...

. … Quebec SLFI objection Effective January 1, 2013, the CRA administers the QST applicable to SLFIs. ...