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CRA Webpage, “Loans and Employee Debt” 14 November 2023-- summary under Subsection 80.4(1) Summary Under Tax Topics- Income Tax Act- Section 80.4- Subsection 80.4(1) relief from imputed interest on small short-term loans made to employees … Non-taxable situation If the loan is received or a debt is incurred because of employment, the interest benefit is not taxable if all of the following apply: Total amount of all loans received is $10,000 or less per calendar year (includes loans of different term durations and principal amounts) Term of the loan(s) is 60 days or less Loan is not received because of shareholdings [i.e., the person or partnership is a shareholder of a corporation, connected with a shareholder of a corporation or a member of a partnership or beneficiary of a trust that was a shareholder of a corporation, and because of such shareholdings, the person or partnership receives a loan from, or incurs a debt to the corporation, a corporation related to that corporation or a partnership of which the corporation or the related corporation was a member] If the term of the loan spans 2 calendar years, the loan will count as part of the $10,000 limit for the year in which the loan was received. ...

If the corporation does not have reasonable knowledge of where the property is being used, or the corporation does not have a permanent establishment in the jurisdiction described in … (a), the gross revenue should be allocated to the permanent establishment to which the person negotiating the lease may reasonably be regarded as being attached. 2.54 Regarding reasonable knowledge, the corporation may have knowledge of the location where the leased property is being used simply by virtue of the relationship with the client. ...

. … [I]t is the longstanding administrative practice of the CCRA that a subsection 15(1) benefit will not be assessed in respect of a benefit arising from the reinvestment of dividends in additional shares under a DRIP, provided that the amount paid for the additional shares is not less than 95% of their fair market value. ...

. … Where a corporation receives a dividend that is deductible in computing its taxable income and the dividend does not benefit from the safe income exception, the determination of whether the dividend will be recharacterized as a capital gain under subsection 55(2) and the purpose test should be consistent with the tax policy underlying section 55. ...

GST/HST Notice 339, “Input Tax Credits Related to Dental Practices,” October 2024-- summary under Section 11.1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part II- Section 11.1 Administrative arrangement with the Canadian Dental Association Under the CRA arrangement made in 1991 with the Canadian Dental Association, a dentist registrant could, for each reporting period in a fiscal year, use an estimate up to a maximum of 35% of the total consideration charged for orthodontic treatments to represent the consideration for the supply of orthodontic appliances and claim input tax credits (ITC) accordingly – but then, at the end of the fiscal year, was required to perform a reconciliation based on the actual amounts charged for orthodontic appliances, and adjust the ITC claims for the year accordingly (keeping in mind that charges for cosmetic services also generated ITCs). ...

Under CRA’s arrangement made in 1991 with the Canadian Dental Association, a dentist registrant could, for each reporting period in a fiscal year, use an estimate up to a maximum of 35% of the total consideration charged for orthodontic treatments to represent the consideration for the supply of orthodontic appliances, and claim ITCs on that basis – but then, at the end of the fiscal year, was required to perform a reconciliation based on the actual amounts charged for orthodontic appliances, and adjust the ITC claims for the year accordingly (keeping in mind that charges for cosmetic services also generated ITCs). ...

. … The expression not ordinarily located primarily means ordinarily located 50% or less. ...

. … 4(b) [Provincial exemptions] With the exception of Quebec, the CRA does not necessarily abide by the provincial exemptions when determining the rate to issue administrative garnishment action. ... Some examples…include situations where there were other sources of income and only one income source was to be subjected to garnishment action, assets that could be readily available to the debtor to generate funds to satisfy the tax debt in full or a substantial portion and the debtor was not cooperating, or situations where the provincial exemption amount would be insufficient to address the amount of arrears. … [T]he CRA felt it was better to treat all debtors, in a similar circumstance, the same to the extent possible. ...

. … A significant number of NPOs violate the incidental profit test or have large equity The results from the review of the randomly-selected organizations suggest that a significant portion of incorporated organizations would fail to meet at least one of the requirements set out in paragraph 149(1)(l)…. ...

. … 3. Where the insurance policy provides a taxpayer carrying on business or practising a profession with a benefit for loss of income earning capacity such as income disability insurance, the premium on such a policy is a personal and living expense which is non-deductible and the benefit received by the taxpayer is not considered to be income subject to tax in his hands. 4. ...