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Activities that fall outside of these categories may not be related to journalism, and will be considered by the CRA on a case-by-case basis. ...

Because it has qualified for the first claim period, the eligible employer is automatically considered to have experienced the required reduction in revenue for the second claim period (April 12 to May 9, 2020). ...

For purposes of paragraph 20(1)(dd), it is immaterial whether the site is land owned by the taxpayer or land being considered for possible purchase by him. ...

When asked as to whether it considered this decision to be portable to the situation where a non-resident person with a branch in Canada wishes that branch to be treated as resident in Canada for purposes of the ETA s. 156 election (presumably to be made with a Canadian corporate affiliate), CRA responded that it was considering the decision’s “impact on section 132,” but that: Subsection 132(2) deems a non-resident person with a permanent establishment in Canada to be resident in Canada “in respect of, but only in respect of activities of the person carried on through that establishment”. ...

27 February 2020 CBA Roundtable, Q.22-- summary under University Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- University Fraser International (re a university not needing to grant degrees regarding a college that is to be affiliated for GST/HST) will be followed on materially similar facts Memorandum 20-3, para. 7 states: An organization is only considered to be operating a college affiliated with a university where there is a formal affiliation agreement that states that the parent organization (the university) agrees to grant degrees to graduates of the affiliated college in exchange for a certain amount of control over the academic standards of, and the courses offered by, the affiliated college. ...

27 February 2020 CBA Roundtable, Q.24-- summary under Subsection 240(1) Summary Under Tax Topics- Excise Tax Act- Section 240- Subsection 240(1) non-resident lessor of equipment delivered in Canada is carrying on business in Canada even if the leased equipment is immediately exported Example 1 in Policy Statement P-051R2 indicates that a non-resident lessor (with a leasing business outside Canada) is considered to be carrying on business in Canada by virtue of a sale-leaseback transaction under which it purchases a vehicle from a resident registrant, with delivery under the sale agreement and under the lease-back to the resident (who will use the conveyance partly in Canada) occurring in Canada, notwithstanding no other significant connecting factors to Canada. ...

CRA found that the registrant was entitled to a full ITC on the acquisition pursuant to s. 202(2) on the basis that the personal use of the passenger vehicle by the employee was to be “considered, in the case at hand, to form part of the registrant's commercial activity by virtue of subsection 173(1)(d) … thereby making the total use of the property exclusively in commercial activity (i.e., 80% commercial activity plus 20% deemed commercial activity), the registrant.” ...

This view has permitted investment funds to redeem their securities once a year based on their NAV and still be considered non-redeemable investment funds. ...

Provided a charity ensures it retains authority on the use of its resources, it will not be considered to be engaged in directed giving. 76. ...

If you are not a citizen or a permanent resident of Canada and your primary place of residence is outside Canada, any residential property that you own in Canada is generally considered to be a secondary place of residence, unless you can prove otherwise. ...