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Consequently … [such] payments … are part of a series of periodic payments and do not constitute an eligible amount within the meaning of section 60.01. ...

(b) or (f) As part of its response to the question as to whether a guaranteed investment certificate or term deposit denominated in Canadian or foreign currency issued by a bank in Canada or a trust company a qualified investment for an RRSP, CRA stated: [I]n general, a guaranteed investment certificate or term deposit, denominated in Canadian or foreign currency and issued by a bank in Canada, would qualify as a bond, debenture, note or similar obligation” specifically described in paragraph (b) …. Furthermore, a guaranteed investment certificate, denominated in Canadian or foreign currency, issued by a trust company incorporated under the laws of Canada or of a province could qualify as a qualified investment under paragraph (f) …. ...

6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 14, 2017-0708511C6 F- T1135 and 162(7) penalty-- summary under Subparagraph 152(4)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) failure to file a T1135 treated as a misrepresentation – but neglect etc. ground to be determined In 2015-0588971C6, CRA indicated that the proposition that “the late-filing penalty of $2,500 under subsection 162(7) applies automatically… is currently under study.” CRA has now indicated that having completed that study, it is: still of the opinion that [the penalty] applies automatically where all the conditions of that subsection are satisfied. … CRA went on to acknowledge the six-year normal reassessment period under s. 152(4)(b.2), and referenced the exception thereto for neglect etc., and stated: Failure to file Form T1135 when required by subsection 233.3(3) constitutes, in the CRA's view, a misrepresentation. ...

During the review period, the CRA continues to administer employee discounts on merchandise in accordance with the administrative policy outlined in Guide T4130, Employers Guide – Taxable Benefits and Allowances …. ...

After indicating that the s. 248(1) definition of business was “intended to clarify and extend the ordinary meaning of the word ‘business’," CRA stated: … Stewart considered how to determine whether or not there is income from a source for the purpose of section 9. ... Ultimately, the question of whether the activities of a taxpayer constitute a "business" remains a question of fact …. ...

. … [T]he CRA policy is not at odds with the decision in … Béarence. CRA officials are expected to be reasonable in their requests for the information and documentation. ...

CRA responded: Generally split income … include[s] amounts that are included in a specified individual’s income in respect of a corporation, partnership or a trust … [and] does not include amounts that are included in the income of a specified individual as a result of the direct ownership of real property. ...

., and distributes the dividend to B Co (a beneficiary) to which A Co is connected – but they cease to be connected corporations by December 31 of that year. ... IV tax exemption did not apply to the dividend received by B Co since the s. 104(19) designation is considered to be effective only at the end of the trust’s taxation year – at which time they were no longer connected. ...

After indicating that this question “is still under review by the CRA,” it stated: In parallel, work is underway at the …OECD … to develop the Crypto-Asset Reporting Framework (the “CARF”), a standardized package that will include reporting requirements to tax administrations and exchange of information procedures related to taxpayers’ transactions with crypto-asset service providers. … A public consultation meeting will be held at the end of May 2022. ...

. … Furthermore, in a situation where it was paragraph 55(2)(c) that applied, rather than paragraph 55(2)(b) … the deemed capital gain realized by the corporation for the taxation year in which the dividend was received from the disposition of a capital property could be distributed by it as a capital dividend only in subsequent taxation years. ...