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(Canada), 24 January 2025 Application pursuant to ss. 18 and 18.1 of the Federal Courts Act under s. 38(a)-- summary under Paragraph 38(a) Summary Under Tax Topics- Income Tax Act- Section 38- Paragraph 38(a) The applicant, who realized a capital gain on a July 2024 sale of an Ontario property, brought this application challenging the 7 January 2025 decision of CRA to administer the Act as if the capital gains inclusion rate increase were in effect, on the grounds inter alia that this would be contrary to the rule of law. ...

Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025-- summary under Subsection 15(2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2) Characterizing as loan 1.14 The determination of whether a loan has been received or a debt incurred is not based on accounting entries, which might not reflect the substance of a transaction. ...

Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025-- summary under Paragraph 15(2.4)(c) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.4)- Paragraph 15(2.4)(c) Purpose of acquiring shares for employee’s own benefit Disposing of shares before the loan is repaid will generally be considered indicative of a purpose other than acquiring shares to be held by the employee for the employee's own benefit, including dispositions to the corporation. ...

Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025-- summary under Paragraph 15(2.4)(a) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.4)- Paragraph 15(2.4)(a) Purpose of acquiring shares for employee’s own benefit Disposing of shares before the loan is repaid will generally be considered indicative of a purpose other than acquiring shares to be held by the employee for the employee's own benefit, including dispositions to the corporation. ...

Income Tax Folio S3-F1-C2 Deemed Interest Benefit on Shareholder Loans and Debts, April 10, 2025-- summary under Paragraph 80.4(3)(a) Summary Under Tax Topics- Income Tax Act- Section 80.4- Subsection 80.4(3)- Paragraph 80.4(3)(a) Third-party interest payments not accommodated 2.14 The exception in s. 80.4(3)(a) does not apply if any party, other than the borrower, made or was required to make any interest payments on the loan. ...

Income Tax Folio S3-F1-C2 Deemed Interest Benefit on Shareholder Loans and Debts, April 10, 2025-- summary under Paragraph 80.4(3)(b) Summary Under Tax Topics- Income Tax Act- Section 80.4- Subsection 80.4(3)- Paragraph 80.4(3)(b) Continued accrual on non-forgiven portion 2.16 Where part of a loan is forgiven, s. 80.4(3)(b) does not obviate the requirement to compute the deemed interest benefit on any portion of the loan that remains outstanding. ...

CRA Webpage, Enhanced reporting rules for trusts and bare trusts: Frequently asked questions, updated on 14 March 2025-- summary under Subsection 204.2(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 204.2- Subsection 204.2(1) Requirement to report non-beneficiary reportable entities (paras. 1.6 and 1.7) Unlike the accommodation by the rules for beneficiaries who are not known or ascertainable with reasonable effort, CRA notes that the Regulations “do not include a relieving provision where the person making the return does not know the identity of a particular reportable entity” (other than a beneficiary). ...

Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025-- summary under Subsection 15(2.17) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.17) Overview 1.18 … In very general terms, where the conditions set out in subsection 15(2.16) are met, subsection 15(2.17) deems that the particular corporation or partnership made a loan to the borrower for the purposes of sections 15 and 80.4, in an amount equal to the funding indirectly provided. ...

GST/HST Memorandum 3-3-5 “Place of Supply in a Province – General Rules for Intangible Personal Property” January 2025-- summary under Subsection 136.1(1) Summary Under Tax Topics- Excise Tax Act- Section 136.1- Subsection 136.1(1) Application of place-of-supply rules can change at the beginning of each lease interval 19. … [S]eparate supplies of intangible personal property that are deemed to be made for each lease interval may be subject to the GST or the HST at a different rate, to the extent that those supplies are deemed to be made in a different province based on the application of the place of supply rules for intangible personal property. ...

GST/HST Memorandum 3-3-5 “Place of Supply in a Province – General Rules for Intangible Personal Property” January 2025-- summary under Paragraph 6(2)(a) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 6- Subsection 6(2)- Paragraph 6(2)(a) Example 5 A student in Ontario with a New Brunswick permanent address purchases for $250 at an Ontario membership desk a six-month membership to use the club’s fitness facilities, which are in both provinces. ...