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Accordingly … business interruption insurance proceeds would generally be included in qualifying revenue and would generally not be considered an extraordinary item. ...

After indicating that where a taxation year has already been assessed on the basis of a fiscal period end, the Act does not have any provision that allows a reassessment to change the FPE, the Directorate went on to state: [T]he … [preamble] wording of subsection 249.1(1) indicates that the purpose of specifying a particular period of time as a fiscal period is that a corporation can choose, within the parameters specified under the subsection, a FPE for preparing its accounts for the purposes of assessment. ...

CRA stated, regarding the requirement that there have been a written agreement entered into before October 9. 2020: [W]hile there is no requirement that the documents be signed … the written documents must show a clear intention to create a binding and enforceable contractual relation, outline all the essential terms and conditions of the agreement, and demonstrate an acceptance in writing by both parties of the terms and conditions. ...

CRA stated that this was “possible … assuming that the Lease includes the same enforceable and binding rights and obligations, and terms and conditions, as the [letter agreement].” ...

…[T]here are other factors that may affect [this] determination …. For example, the sublease itself may contain a condition stipulating that the agreement would not take effect until the signature of the landlord was procured. ...

CRA stated: … [I]t appears that the requirements to use the rule in paragraph 125.7(4)(d) could be met since all of Opco’s revenue would be considered to be derived from persons with which Opco does not deal at arm’s length (the participants of the joint venture, Holdco 1 and Holdco 2). ...

After noting that NR-Beneficiary was subject to taxation under the Barbados Income Tax Act, 1968 on its “income from sources outside Barbados … only to the extent a benefit is obtained in Barbados from that income in the form, among others, of a remittance of money or an importation of property,” i.e., on a “remittance basis,” CRA indicated that NR-Beneficiary qualified as a resident of Barbados, i.e., as “a person must be subject to the most comprehensive form of taxation as exists in the relevant contracting state”: That is because, even if, under the law in force in Barbados, the taxation of the Trust Income may be deferred until a benefit is obtained in the form of a remittance of money or an importation of property in Barbados, it is our understanding that the NR-Beneficiary remains, nonetheless, “liable to tax” in Barbados in respect of its worldwide income. ...

. … For CEWS purposes, when the payment is added by the employer, which is an eligible entity, to the basic salary or wages included in each paycheck of an eligible employee, we will consider that the eligible entity has paid the payment to an eligible employee in respect of the same week as the related salary or wages are paid. ...

. … [T]he employees' travel is therefore not for the purpose of travelling away from the municipality and, where applicable, the metropolitan area where the employer's establishment was located. ...

In this regard, the Directorate noted that decisions such as Clibetre and Orlando indicate that “where requested changes to elements of the taxpayer’s return of income are denied, and there is no change to the tax payable previously assessed … there has been no ‘reassessment’ of tax by the Minister,” and such denial is instead “simply a notification that a reassessment has not been done” (“even if the notification is titled a ‘Notice of Reassessment’.”) ...