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Therefore, if both spouses are considered to have beneficial ownership … they would both be required to file the election …. ...

The application of subsection 245(2) could be considered if the Pipeline Planning is structured to avoid the application of section 84.1 …. ...

It further indicated: [W]here a taxpayer’s requested amendment is fully reflected (or accepted by the Minister), the Minister will not be considered to have ascertained a different loss amount from the taxpayer. ...

Regarding Alta Energy: The SCC considered a matter central to the CRA’s ongoing efforts to protect Canada’s tax base and the integrity of its tax treaties. ...

The Directorate then stated: If a person who is subject to remittance basis taxation in Barbados files a return of income in Barbados contrary to the application of the law in force in Barbados, it is our view that the income reported on that return … would not be considered “taxed” in Barbados for the purposes of Article XXX(5) such that the benefits of the Treaty would not apply to the Income. ...

21 September 2021 Internal T.I. 2019-0807491I7- Subsections 93.1(5) and (6)-- summary under Subsection 93.1(5) Summary Under Tax Topics- Income Tax Act- Section 93.1- Subsection 93.1(5) access to ss. 93.1(5) and (6) needed for a US partnership to be considered to have a qualifying interest in a sister Opco paying it interest Canco held 100% of LLC2 through a US partnership (USP) and had an indirect 37% interest in USOpco. ...

Ss. 93.1(5) and (6) could only apply to such interest if, pursuant to the coming-into-force (CIF) provision for ss. 93.1(5) and (6) (which otherwise applied only to the 2013 and subsequent taxation years), it could be considered that the taxpayer (USP) had “elected[ed] in writing” and timely “file[d] the election with the Minister” to have ss. 93.1(5) and (6) apply to those earlier years. ...

7 October 2022 APFF Roundtable Q. 7, 2022-0942731C6 F- Permanent establishment and teleworking-- summary under Paragraph 400(2)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 400- Subsection 400(2)- Paragraph 400(2)(b) employer is required to be carrying on business through an employee’s cottage to be considered to have a PE there under Reg. 400(2)(b) Mr. ...

(b) Is the safe income from the sale of the assets lost or will it be considered in a future computation of safe income? ...

7 October 2022 APFF Financial Strategies and Instruments Roundtable Q. 9, 2022-0940951C6 F- FRB créée par testament après 2015-- summary under Subsection 118.1(5.1) Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(5.1) a gift by will of a capital interest in a charitable remainder trust can be claimed only by the GRE, not the deceased CRA confirmed that where an individual has by will made a gift to a qualified donee of the capital interest in a charitable remainder trust (“CRT”), such capital interest is not considered for purposes of s. 118.1(5.1) to have been acquired by the graduated rate estate (“GRE”) on or as a consequence of the individual's death, so that s. 118.1(5.1) is unavailable to permit a donation credit to be claimed in the T1 return of the deceased for the year of death or the preceding year, and so that it is only the GRE which will be able to claim such credit for the taxation year in which the gift is in fact made or for any of the five subsequent taxation years. ...