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If the CRA accepts a disclosure as having met the conditions set out in this policy, it will be considered a valid disclosure and the taxpayer will not be charged penalties or prosecuted with respect to the disclosure. ...

However, we will not permit revisions when, in the Department's view, the main purpose of the amended election is:...retroactive tax planning, such as taking advantage of losses or tax credits not considered when the election was originally filed. ...

Has it considered pre-acquisition PUC planning more recently? Consider the following: Foreign Parent subscribes for shares of its wholly-owned Canadian acquisition company (CanAc) having full paid-up capital. ...

In this case, it is unlikely that the period could be considered to end later than the commencement of the negotiations in February of year 1. ...

., 10 or more residential units, the entire complex is considered to meet the expected one-year occupancy test if substantially all of the units (90% or more) meet that test. ...

CRA indicated that the Land-owner is considered under s. 136(2) be making two supplies; of the Retail Portion, which is a taxable supply; and of the Residential Portion, which would be exempt under Sched. ...

The right of the creditor should not be considered as a "specified right" if the net proceeds of the exercise of that right are to be applied to one or more of those debts. ...

CRA responded: Although it may be possible to have more than one builder of a residential complex at the same time, based on the limited information provided, it is not clear how both persons A and B would be considered builders. ...

Guidance on the application of the split income rules for adults 15 December 2017 CRA Webpage-- summary under Reasonable Return Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Reasonable Return Deference to taxpayer’s good-faith efforts to determine Reasonable Return In determining whether the payment is a Reasonable Return [defined as a reasonable return based on listed criteria or “such other factors that may be relevant” (the "Reasonableness Criteria")], the Agency does not intend to generally substitute its judgment of what would be considered a reasonable amount unless there has not been a good faith attempt to determine a reasonable amount based on the Reasonableness Criteria. ...

This repayment of the FA 1 Loans may not be considered to result in the repayment of the Deemed Loans, in which case, there could be a double income inclusion to Canco for the year: s. 90(12) applies to bring into income the amount claimed in the previous year as a s. 90(9) deduction respecting the Deemed Loan; ands. 90(6) includes each FA 1-New Specified Debtor Loan in Canco's income. ...