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16 April 2024 Internal T.I. 2023-0964831I7- Guaranteed payments to non-resident athletes-- summary under Subparagraph 115(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(i) guaranteed salary payments received by a US-resident member of a Canadian team while not in Canada were not taxable in Canada A resident of the US, who had entered into a 6-year employment contract (covering years 20X1 to 20X6) with a Canadian team, suffered a serious injury in the 20X3 season but, pursuant to a guaranteed payment clause in his contract, continued to receive full salary for the remaining contract term notwithstanding that he ceased playing for that team – and was released by that team in 20X4 and hired by a US team in 20X5. ...

CRA indicated that such a deemed resident trust is not subject to Part XIII tax on amounts paid or credited to it, but is not considered to be resident in Canada for the purposes of determining the liability of a person other than the trust to withhold and remit under s. 215 – so that there is still a requirement to withhold and remit Part XIII tax on the rent paid to such trust. ...

4 June 2024 STEP Roundtable Q. 13, 2024-1007851C6- DRT and Section 216-- summary under Paragraph 94(3)(g) Summary Under Tax Topics- Income Tax Act- Section 94- Subsection 94(3)- Paragraph 94(3)(g) although resident tenant required to withhold on rent to s. 94(3), s. 94(3)(g) applies to such withholding Regarding the application of Part XIII to a non-resident trust that is deemed to be resident in Canada pursuant to s. 94 and which owns a Canadian rental property, CRA indicated that such trust is not subject to Part XIII tax on amounts paid or credited to it, but is not considered to be resident in Canada for the purposes of determining the liability of a person other than the trust to withhold and remit under s. 215 – so that there is still a requirement for the Canadian tenant(s) to withhold and remit Part XIII tax on the rent paid by them. ...

. … CRA went on to note: The reduction in ACB for foreign taxes paid on behalf of a partner may occur prior to the addition to the ACB for the allocation of foreign income to the partner which is made on the first day of the following fiscal period. ...

CRA has viewed a société en commandite simple in France as a partnership, irrespective of whether it has irrevocably elected to be taxed as a corporation in France – and similarly, the recent enactment of reverse hybrid rules in Luxembourg would not be determinative. ...

CRA has viewed a French société en commandite simple as a partnership, irrespective of whether it has irrevocably elected to be taxed as a corporation in France – and similarly, the recent enactment of reverse hybrid rules in Luxembourg would not be determinative. ...

In that case, the municipality is merely acting as a conduit for the other person, and it is our view that amounts received by the municipality on behalf of the other person do not qualify as gifts to a municipality …. ...

CRA indicated that the first alternative did not satisfy the requirement, for the equipment to qualify as Class 53 property, that it be used in the manufacturing or processing of goods for sale – as the goods (the dental restorative products) instead were used in providing a dental service. ...

. … In such case, the CRA would generally rely on the relevant foreign corporate or company law and the details of the plan of conversion to determine whether there is a continuity of existence on the Conversion. ...

It claims an Atlantic Investment Tax Credit (“AITC”) pursuant to s. 127(9) of $750,000, being 10% of the capital cost, again reduced to $7,500,000 by the NS CITC “government assistance” – and receives the AITC by way of credit against federal tax payable in the current year or during the carryforward or carryback period. ...