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Underused Housing Tax Notice UHTN9 Exemptions for Residential Properties That Cannot be Used Year-round February 2023-- summary under Paragraph 6(7)(d) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Underused Housing Tax Act- Section 6- Subsection 6(7)- Paragraph 6(7)(d) Example 2 A property fronting on a road which is impassable throughout the winter season is considered to be seasonally inaccessible. ...

No. 3, p. 9, ¶1105)-- summary under Subsection 127.52(1) Summary Under Tax Topics- Income Tax Act- Section 127.52- Subsection 127.52(1) Where a taxpayer claims the full deduction for which he is eligible, such amount will be considered to have been deducted for purposes of s. 127.52(1)(h) notwithstanding that a lesser deduction would have produced nil taxable income. ...

Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025-- summary under Paragraph 15(2.4)(c) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.4)- Paragraph 15(2.4)(c) Purpose of acquiring shares for employee’s own benefit Disposing of shares before the loan is repaid will generally be considered indicative of a purpose other than acquiring shares to be held by the employee for the employee's own benefit, including dispositions to the corporation. ...

Income Tax Folio S3-F1-C1, Shareholder Loans and Debts, April 10, 2025-- summary under Paragraph 15(2.4)(a) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.4)- Paragraph 15(2.4)(a) Purpose of acquiring shares for employee’s own benefit Disposing of shares before the loan is repaid will generally be considered indicative of a purpose other than acquiring shares to be held by the employee for the employee's own benefit, including dispositions to the corporation. ...

For this purpose, a financial institution will not be considered to have solicited customers outside of Canada merely because it operates a website, provided that the website does not specifically indicate that the financial institution provides accounts or services to non-residents of Canada. A financial institution will also not be considered to have solicited customers outside of Canada if it advertises in print media or on a radio or television station and the advertisement is distributed or aired outside of Canada, as long as the advertisement does not specifically indicate that the financial institution provides accounts or services to non-residents of Canada. ... An investment entity will not be considered a member of an expanded affiliated group as a result of contributing seed capital (that is, an initial investment that is intended as a temporary investment) by a member of the group if all of the following conditions are met: The member of the group that provides the seed capital is in the business of providing seed capital to investment entities that it intends to sell to unrelated investors. ...

Generally, applications by corporations with gross revenue in excess of $250 million in at least two of their last five taxation years, and any related entities, will be considered under the Limited Program. 18. Additionally, in all cases, the following factors may be considered when determining under which category a VDP application should be processed: the dollar amounts involved; the number of years of non-compliance; the sophistication of the registrant; and how quickly the registrant took corrective measures to address their non-compliance upon its discovery. 19. ... If a VDP application is accepted as having met the conditions set out in paragraph 29, it will be considered a valid disclosure. ...

(ii) Second condition We are of the view that the second condition for the application of section 84(2) would be satisfied since the sale of the assets of Watch4Net, represented primarily in terms of value by the sale of the intellectual property, should be considered to result in the winding-up or discontinuance of the business of Watch4Net. ... They considered that the property acquired by the Tremblay family was different, in its legal form, than the property that was held by the corporation before the transaction, although the economic terms were substantially the same and consequently, subsection 84(2) could not apply. ... This was a well-considered scheme adopted on the advice of professional advisers after other means of extraction of the undistributed income (…) However, it is the CRA's view that the strict and literal approach to the interpretation of subsection 84(2) adopted by the Federal Court of Appeal in Vaillancourt-Tremblay has clearly been rejected by that same court in MacDonald. ...

Accordingly, the advertising service was considered to be performed in part in Canada with the result that it was deemed under s. 142(1)(g) to be a supply made in Canada. ...

.- Q.26-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (d) Where a well that originally was drilled in 1988 is re-entered in 1993 and drilled to a deeper zone resulting in the discovery of a new pool, well recompletion costs related to the portion of the well that was drilled in 1993, the portion of the well that had been drilled in 1988 and the level where production was taken prior to discovery of the new reserves, would be considered to be CEE. ...

93 CPTJ- Q.5-- summary under Paragraph 12(1)(r) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(r) The word "obsolescence" in s. 12(1)(r) is considered to refer to an amount respecting obsolescence of fixed assets where such amount is included as overhead in computing the value of the taxpayer's closing inventory for financial statement purposes, and does not refer to an amount deducted for obsolete goods that themselves form part of inventory. ...