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Supreme Court for a declaration that a purchaser of the foreclosed properties would be considered to be acquiring them from the (resident) banks rather than from the non-residents (so that s. 116(5) would not apply.) ...

CRA responded that “only the expenses that are reasonable to consider to be attributable to the activities generating the [SCI] income … should be considered” as deductions from the SCI income. ...

In particular, where both the business and service income are nil, it will not be considered to satisfy the requirement that less than 90% of its business income is from the provision of services. ...

21 March 2019- 12:51am CRA continues to accept deliberate triggering of CDA additions for distribution purposes Email this Content CRA noted that the approach of the GAAR Committee to surplus-stripping has changed significantly: Since 2015-0610701C6 the Committee has considered that it will no longer recommend the application of GAAR to certain corporate reorganizations through which there is a deliberate triggering of a capital gain in order to distribute a capital dividend to its shareholders. ...

., the cash boot is considered to be sufficient to bust the IRC s. 351 rollover. ...

Generally, the acquisitions and dispositions during the normal course of business would not be considered acquisitions or dispositions of separate businesses. ...

CRA noted that this was similar to Example 9 of CRA’s split-income guidelines, and stated that they both could be considered to be actively engaged in the business – but indicated that this was a question of fact. ...

26 August 2020- 11:19pm CRA comments further on the meaning of a “travel restriction under its COVID Guidelines Email this Content CRA's Guidance on international income tax issues raised by the COVID-19 crisis provides relief respecting adverse impacts of COVID-related travel restrictions on such matters as being considered to have become a Canadian resident. ...

2 September 2020- 12:00am CRA indicates that there generally is no COVID relief from the obligation on non-resident corporations carrying on business Canada to file tax returns Email this Content CRA indicated that its general expectation was that non-resident corporations resident in a non-treaty jurisdiction, which are considered to be carrying on a business in Canada only because of COVID Travel Restrictions, nonetheless would file a tax return- but that the corporation could always seek to try to persuade CRA to show some flexibility in circumstances not covered in the COVID Guidelines. ...

21 September 2020- 10:35pm CRA indicates that that “US EIP” payments received under the CARES Act are not income from a source Email this Content A permanent resident of Canada receiving “US EIP” payments under the CARES Act, being a refundable tax credit for U.S. citizens and U.S. resident aliens that is recaptured if adjusted gross income reaches certain thresholds was not taxable thereon given that: The amount is considered an advanced payment of a 2020 refundable tax credit, and therefore is likely not income from a source under the Income Tax Act. ...