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University of New Brunswick – Tax Court of Canada finds that a post-doctoral fellow was not an employee of the University

5 June 2023- 11:13pm University of New Brunswick – Tax Court of Canada finds that a post-doctoral fellow was not an employee of the University Email this Content Bocock J indicated that whether annual awards made to a post-doctoral fellow (PDF) of the University were employee remuneration for CPP and EI purposes turned on a determination of their “dominant purpose,” namely, “whether on balance the payments were made on account of monetary assistance to enhance the PDF’s education and research skills or paid as income in consideration of various services provided by the PDF to the University.” ...

CRA confirms the application of s. 7(1.31) to the acquisition and immediate sale of RSU shares

An employee who acquired 10 common shares of the public-company employer, was also issued, for no consideration (other than services rendered), 10 restricted stock units (RSUs) of the employer under an agreement to which s. 7(1) applied. ...

CRA discusses the application of the procedural provisions for adjusting CEWS and CERS claims

Similar considerations applied to the CRHP and CERS benefits. Neal Armstrong. ...

Amex Bank – Tax Court of Canada finds that costs of Amex’ points program were inputs to its exempt credit card revenues, and did not generate ITCs

Amex submitted that the free supply rule in s. 141.01(4) applied to characterize the supply of the rewards as a taxable supply, on the basis that (i) the supply of rewards to Members was made for no consideration, and (ii) the purpose of making such supply was to facilitate the activities of the Members. ...

CRA finds that a company which negotiated agreements between credit card companies and merchants was supplying a GST/HST-exempt service

13 July 2023- 10:44pm CRA finds that a company which negotiated agreements between credit card companies and merchants was supplying a GST/HST-exempt service Email this Content “Acquirers,” who used funds from the customer’s credit card issuer to provide funds to pay merchants for their customers’ purchases, retained the Company to find merchants and negotiate agreements with them to receive such services of the Acquirer, in consideration for a fee based on the number of merchant transactions processed by the Acquirer. ...

CRA has published a memorandum on when corporations and partnerships are closely related for purposes of the ETA s. 156 election

23 July 2023- 11:37pm CRA has published a memorandum on when corporations and partnerships are closely related for purposes of the ETA s. 156 election Email this Content CRA has published a new memorandum regarding when Canadian partnerships and corporations will be considered to be closely related to each other for purposes of the ETA s. 156 (nil consideration) election. ...

LBL Holdings – Tax Court of Canada finds that “flash” sales occurring on a reserve for immediate delivery to the trucks of non-Indians were exempted from GST

As soon as LBL delivered the products to the store vicinity, and it received the cash consideration, the products were loaded onto the waiting trucks of customers, in turn, of Roberta MacNaughton. ...

There is a concern that redeeming the preferred shares of a related individual at the commencement of a butterfly reorganization would oust the butterfly exception

There is greater certainty if Dad instead transfers his DC preferred shares to each of the TCs in consideration for voting shares of the TCs, with the TCs then redeeming those preferred shares. ...

Northbridge Commercial Insurance – Federal Court of Appeal finds that zero-rating for fleet insurance could be based on the relative expected claims experience for US accidents

The Tax Court had not considered the evidence relating to this point, and the matter was referred back to it for such consideration. ...

Sommets du Mont-Tremblant – Court of Quebec finds that an in-kind damages payment should be treated the same as a sale of the transferred property

In the settlement, it agreed that, in consideration for the $400,000 referred to above, it would transfer a particular property (not covered by the option) to Solstice. ...

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