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Canafric – Tax Court of Canada finds that developing new pie recipes was SR&ED

Regarding two of the projects where the CRA technical advisor considered there to be insufficient documentation, any such gaps were filled by the testimony, with Rossiter C.J stating: Documentary evidence is not mandatory. ...

CRA indicates that joint tenants of a newly-constructed residence are each responsible for the GST/HST on 100% of the property’s FMV

CRA found that since each Owner, as a joint tenant, was considered at common law to own the entire property, and given that the self-supply rule in ETA s. 191(1) applied to the whole residential complex and not to an interest therein and the rule does not provide for the division of the tax payable on the deemed supply among multiple joint-tenant builders, each co-owner was subject to tax on the FMV of the whole building. ...

CRA finds that a non-resident supplied software licences directly to Canadian users rather than to non-resident sales representatives

However, CRA considered that Aco was not making supplies of the licences to the representatives but rather to the end-user in Canada and that GST/HST applied to such supplies. ...

It may be desirable to deliberately taint a non-resident estate (through a small bequest to a distant Canadian relative) as a s. 94(3) trust so as to access s. 164(6)

16 August 2023- 11:09pm It may be desirable to deliberately taint a non-resident estate (through a small bequest to a distant Canadian relative) as a s. 94(3) trust so as to access s. 164(6) Email this Content CRA has considered (e.g., in 2010-0384531E5) that a non-resident estate of a deceased resident may only use s. 164(6) to reduce or offset the deceased’s gain under s. 70(5), by carrying back a capital loss realized by it on shares, where such shares are taxable Canadian property (TCP). ...

The Joint Committee recommends that the Act be amended to exclude unconditionally repayable loans from "government assistance"

27 August 2023- 11:36pm The Joint Committee recommends that the Act be amended to exclude unconditionally repayable loans from "government assistance" Email this Content CAE indicated that a government loan lacking sufficient "ordinary commercial terms" – including one that was made otherwise than to promote the governmental commercial interests or that has a below-market interest rate – will be considered "government assistance" within the meaning of ss. 12(1)(x) and 127(9). ...

The s. 237.5 reporting rules lack a materiality threshold

., the reasonableness of a royalty may be considered in light of inter-affiliate charges for tangible goods. ...

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

The particular issue is that it might be considered that this redemption entailed the acquisition of property by DC. ...

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. ...

CRA agrees with CAE

8 November 2023- 10:49pm CRA agrees with CAE Email this Content CAE indicated that a government loan lacking sufficient "ordinary commercial terms" – including one that was made otherwise than to promote the governmental commercial interests or that has a below-market interest rate – will be considered "government assistance" within the meaning of ss. 12(1)(x) and 127(9). ...

CRA finds that a recent change of a home from rental to principal-residence use cannot ground an FHSA withdrawal

Accordingly, the individual would be considered to have acquired the home more than 30 days previously even if he withdrew from his FHSA immediately after the deemed change in use, so that the “qualifying withdrawal” definition would not be satisfied. ...

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