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CRA Comments Generally, to be considered a supply of intangible personal property (IPP) that relates to tangible personal property (TPP), there must be a direct connection between the IPP and the TPP. ... Subject to the definition of real property in subsection 123(1) of the ETA, to be considered a supply of IPP that relates to real property for purposes of section 9 of the Regulations, there must be a direct connection between the IPP and the real property. ... VendorCo will not pay or receive any consideration from Corporation A and Corporation B in connection with these agreements. ...

Official Response 26 November 2013 CTF Round Table, Q. 5, 2013-0507961C6 Q5(b) – Article XXIX-A of the Canada-US treaty – Active trade or business test Paragraph 3 contains the “active trade or business test”, which if met, entitles certain non-qualifying persons to treaty benefits in respect of income derived from the other contracting state in connection with or incidental to that trade or business. ...

The purpose will be examined in light of all the circumstances, looking at the perspective of both the payer of the dividend, and the recipient, to determine: what does the taxpayer intend to accomplish with a reduction in value or an increase in cost; how would such reduction or increase in cost be beneficial to the taxpayer; and what actions did the taxpayer take in connection with such reduction in value or increase in costs. ...

What is the current CRA work situation in connection with the conduct of international audits and requests for foreign based information? ...

What is the current CRA work situation in connection with the conduct of international audits and requests for foreign based information? ...

Q.1- Allocation of safe income to discretionary dividend shares At the 2016 CTF Annual Conference, the CRA indicated that it was conducting a study in connection with the proper allocation of safe income in circumstances involving a corporation that has issued shares that are entitled to discretionary dividends. ... In connection with this use, the purpose test will be met if the borrowed money replaces capital (contributed capital or accumulated profits) [when we are referring to contributed capital, our starting point is the legal stated capital] that was being used for eligible purposes that would have qualified for interest deductibility had the capital been borrowed money. ...

The donor will also wish to ensure that the value of any advantage received in connection with the gift can be verified so that an amount can be recognized as a qualifying amount of a gift. ... In addition, the tax consequences under paragraphs 84.1(1)(a) and 84.1(1)(b) will apply only if the shares of the capital stock of Target had an increase in value prior to 1971 or a capital gains deduction was claimed by the individual or a person not dealing at arm's length with the individual in connection with a previous disposition of the shares of the capital stock of Target. ...

What actions has Parent taken in connection with the reduction in value of the shares of the capital stock of Target? ... Official Response 2 November 2023 APFF Roundtable Q. 12, 2023-0982931C6 F- APFF- Congrès 2023- Table ronde sur la fiscalité Q.13 Bankruptcy court approval of assessments Trustee of Girard, 2014 QCCA 1922, stated, in connection with the Bankruptcy and Insolvency Act ("B.I.A. ...

This would include files such as an employee’s email inbox, outbox and other related folders in connection with internal communications between CRA auditors or appeals officers with either headquarters officials, Department of Justice officials, Department of Finance Officials, etc. b) What steps are taken to safeguard relevant CRA communications that have not been flagged or associated to a particular file before such an employee’s departure? ... In the alternative, what is causing the considerable delays (or inaction/contact from CRA) and what, if anything, is CRA considering to improve and expedite this process in connection with late-filed elections under section 156 of the ETA? ... In addition, the non-resident also buys and sells TPP exclusively in the US, with no connection to Canada or the purchases and export sales in Canada noted above. ...