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This is a question of fact …. Similarly, in other situations where an eligible entity pays an amount that is rent for the use of, or the right to use, an area or space that is a portion of a larger area, the amount paid by the eligible entity as rent may be a qualifying rent expense …. ...

. … However … where salary and wages are only reflected by journal entry as an expense by the employer with a corresponding credit to a due to shareholder loan account, such salary and wages are not considered eligible remuneration paid to an eligible employee for purposes of subsection 125.7(2). ...

. … With respect to a building … the use of its square footage is generally an accepted factor that is given significant weight in determining the particular use to which a building is put. ...

Regarding the deductibility of amounts paid after the time of the order, the Directorate stated: [W]here the lump-sum amount is paid pursuant to a court order that establishes a clear obligation to pay retroactive periodic maintenance for a specified period prior to the date of the court order … the lump-sum payment will not, in and of itself, change the nature of the underlying legal obligation of periodic maintenance payments and, if all other requirements are met, the lump-sum amount paid will be deductible to the payer according to the formula in paragraph 60(b) …. ...

. … [Here] paragraphs 161(7)(a) and (b) of the Act do not apply and assuming that the non-capital losses are sufficient to completely offset the increase in income, the taxpayer’s taxable income will not change. … Consequently, the tax calculation will not change, and there will be no arrears interest charged on the reassessment. ...

29 February 2024 Internal T.I. 2023-0987941I7- Amendments to GAAR and Advance Income Tax Rulings-- summary under Subsection 84(2) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(2) CRA after the GAAR amendments will continue to rule on post-mortem pipelines complying with its published policies, but not on inter vivos surplus stripping by individuals Regarding the status of post-mortem pipeline transactions following the amended GAAR rule, the Directorate stated: The Directorate does not consider the use of a pipeline transaction as a means to preserve the capital gain arising on the death of a shareholder while limiting double taxation on the subsequent distribution of Opco’s assets to be a … [GAAR] abuse …. ...

29 February 2024 Internal T.I. 2023-0987941I7- Amendments to GAAR and Advance Income Tax Rulings-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) CRA will continue to issue post-mortem pipeline rulings following the GAAR amendments, but will not rule on surplus stripping by individuals Regarding the status of post-mortem pipeline transactions following the amended GAAR rule, the Directorate stated: The Directorate does not consider the use of a pipeline transaction as a means to preserve the capital gain arising on the death of a shareholder while limiting double taxation on the subsequent distribution of Opco’s assets to be a … [GAAR] abuse …. ...

The Directorate found that if the tokens were held in a business on income account: [A] deposit of the Deposited Tokens, redemption of the Receipt Tokens, and sale of the Receipt Tokens for goods constitute barter transactions in accordance with … IT-490. ... Similarly, if the taxpayer sold the Receipt Tokens in exchange for money, the realization principle should typically apply such that the transaction is a taxable event …. ...

Furthermore, the Agency cannot be forced to agree to process an amended return reflecting a judgment handed down by the Tax Court of Canada under the Informal Procedure because such a judgment does not constitute binding jurisprudence according to … section 18.28 of the Tax Court of Canada Act …. ...

The Directorate responded: [T]he penalties under subsections 162(7.01) and 162(7.02) will be calculated from the expiry of the filing deadline … where that information return is made after the extension date determined by the Minister pursuant to subsection 220(3). ... For example, a person who fails to complete 1,000 T4 Slips- Statement of Remuneration Paid and 50 T4SUM Summary of Remuneration Paid within the time prescribed … would be liable to a penalty under subsection 162(7.01) on a total of 1,050 information returns of the same type. ...