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CRA confirms that there are no ITCs for appliances acquired during the construction of a rental residential complex

14 March 2023- 11:03pm CRA confirms that there are no ITCs for appliances acquired during the construction of a rental residential complex Email this Content CRA confirmed that since appliances and common area furniture and equipment that are acquired in connection with the construction of, say, a residential complex such as an apartment building and which do not become fixtures, will be considered to have been acquired for the purpose of the intended exempt rental of the completed units, no input tax credits will be available. ...

Serres Toundra – Court of Quebec finds that a greenhouse operation is farming, not manufacturing or processing

5 February 2024- 10:58pm Serres Toundra – Court of Quebec finds that a greenhouse operation is farming, not manufacturing or processing Email this Content The Quebec manufacturing and processing credits claimed by Serres Toundra in connection with equipment acquired for use by it in its greenhouse cucumber-growing operation turned on whether such equipment was Class 29 property. ...

Foix – CRA reiterates that Foix overruled a more restrictive approach to s. 84(2) in some earlier cases (and restricts Geransky)

Now, in brief oral comments when a question about this case was repeated, CRA indicated: the reasons in Foix should be carefully considered in connection with any proposed hybrid sale (with exception of transactions identical to those in Geransky); the decision reinforces the broad scope of s. 84(2); and it represents a departure in some respects from the more restrictive view of s. 84(2) evident in some earlier cases. ...

CRA finds that s. 143.2(15) authorized it to open-up a statute-barred year to deny the carryback of a loss which it will deny under s. 143.2

In finding that, by virtue of s. 143.2(15), the individual’s 2016 taxation year could be reassessed beyond the normal reassessment period to deny the carried-back loss, the Directorate stated that “such carryback is closely linked to an adjustment in connection with a tax shelter investment and is necessary and required for the purposes of section 143.2.” ...

CRA references the notice clause in a services contract in determining the place-of-supply for HST purposes (and implicitly acknowledges that nutritional consulting’s purpose is maintaining health)

CRA ruled that the provision by a licensed dietician of “consultant nutrition services” to a registered charity (presumably in connection with a redacted charitable undertaking of assisting needy individuals) qualified for exemption. ...

CRA indicates that a kilometer-based minimum car allowance must be intended to compensate for actual expenses

11 September 2016- 10:21pm CRA indicates that a kilometer-based minimum car allowance must be intended to compensate for actual expenses Email this Content S. 6(1)(b)(x) deems an employee’s car allowance to be unreasonable if it “is not based solely on the number of kilometres for which the vehicle is used in connection with or in the course of the office or employment.” ...

Joint Committee Submission provides illustrations of the potential lack of integration under the new s. 55(2) rules and potential circularity issues arising on late capital dividend elections

The submission also illustrates the uncertainty regarding potential circularity arising in connection with late capital dividend elections: after the generation of a full dividend refund on a dividend paid to an individual so that the paying Holdco becomes subject to a s. 55(2) capital gain, a late s. 83(2) election is made to convert part of the dividend into a capital dividend based on s. 55(2) having generated a capital gain – but this reduces the amount of the s. 55(2) gain. ...

Barrick Gold – Tax Court of Canada finds that gains from closing out gold hedges on the sale of a mine were included in mining production profits

Paris J found that the forwards had a sufficient connection with Barrick’s Doyon mining operation, given that they were entered into in the course of that business to hedge against price fluctuations respecting the production, for the hedging gains to be income from that production. ...

The scope of the s. 212(3.6)(b) rule for converting royalties into interest is unclear

It is not clear how a logical or legal connection between interest, on the one hand, and...royalties, on the other, can exist as suggested by paragraph 212(3.6)(b). ...

S. 95(2)(a)(ii)(D) is drafted too restrictively in light of the underlying policy to extend s. 95(2)(a)(ii)(B)

The requirement for a throughout-the-year connection between FA2 and FA3 can pose difficulties for mid-year reorganizations. ...

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