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May 2019 CPA Alberta CRA Roundtable, General Session – Q.4-- summary under Subsection 248(7) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(7) CRA treats a mailed or couriered item as having been received by it five days before the delivery date After referring to s. 248(7), the questioner asked when a return is considered delivered to CRA by Canada Post’s Expedited Parcel service. ...

A business input that might be considered an indirect input for cost allocation purposes (for example, certain overhead expenses) is a direct input for purposes of section 141.02 if the business input is not an excluded or exclusive input and can be attributed in whole or in part to the making of a particular supply or supplies. ...

Underused Housing Tax Notice UHTN15, Questions and Answers About the Underused Housing Tax, 17 April 2023-- summary under Dwelling Unit Summary Under Tax Topics- Other Legislation/Constitution- Federal- Underused Housing Tax Act- Section 2- Dwelling Unit Need for private facilities (paras. 1.24, 1.35, 1.36) Boarding or lodging houses are not considered to be dwelling units due to the lack of “separate and self-contained sets of private living quarters.” ...

Each situation must be considered on its facts to make this determination. ...

CRA Webpage, Enhanced reporting rules for trusts and bare trusts: Frequently asked questions, updated on 14 March 2025-- summary under Paragraph 150(1.2)(a) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.2)- Paragraph 150(1.2)(a) Scope of 3-month trust 2.5 … The following trusts are considered to have been in existence for less than three months at the end of the taxation year: Trusts that ceased to exist during the particular taxation year, at a date which is less than three months after the trust was created Trusts that were created less than three months before the end of the particular taxation year. ...

However, the payment is considered scholarship income. Example 3: non-inclusion of termination damages An individual and an employer sign an employment contract that…does not provide for any payments at or after the end of employment. ... However, since the amount was compensation for the loss of employment, the payment is considered a retiring allowance…. ...

The relationship between the service and the real or tangible personal property must be more direct than indirect for the service and the property to be considered by the Department to be "in respect of" each other for purposes of paragraphs 7(d) and (e) and paragraphs 23(b) and (c) of Part V of Schedule VI. ... The following are examples of services that are considered to be in respect of real property for purposes of Part V of Schedule VI: services physically performed on the real property (e.g., construction and maintenance); services that enhance the value of the real property, affect the nature of the real property, relate to preparing the real property for development or redevelopment, affect the management of the real property, or affect the environment within the limits of the real property (e.g., engineering, architectural services, surveying and subdividing, management services, security services); services related to; the transfer or conveyance of the real property or the proposed transfer or conveyance of the real property (e.g., real estate services in relation to the actual or proposed acquisition, lease or rental of the real property, legal services rendered to the owner or beneficiary or potential owner or beneficiary of real property as a result of a will or testament); a mortgage interest or other security interest in the real property; or the determination of the title to the real property. ...

[W]e would likely conclude that the LP in scenarios 1 and 2 are ILPs and further information would be required to determine if the LP in scenario 2 is no longer considered to be an ILP. With respect to scenario 4, we would likely conclude that the LP is not an ILP and further information would be required to determine if the LP in scenario 4 is considered an ILP at a later time. ...

An organization that is commencing operations, or is considering commencing operations, will be considered to be operated primarily for the purposes of meeting the “operated primarily” requirement if its intent is to primarily offer correspondence courses, or instruction in courses, that develop or enhance students’ occupational skills. ... A sole proprietor, such as a teacher or a coach, who has a contract with a vocational school to provide a service of instruction as one of the sole proprietor’s business revenue streams is not considered a vocational school for purposes of that contract. ...

The medical professional corporations are each considered the employer on a proportionately agreed upon basis in respect of the employees. ... Thus, when that place is situated outside Canada, that person will not generally be considered as being “employed in Canada”. ...