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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. ...

8 March 2018 CBA Commodity Taxes Roundtable, Q.7-- summary under Money Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Money CRA reviewing whether crypto-currencies are "money" Does the position in 2013-0514701I7, that “Virtual currencies, such as Bitcoins, are not considered to be a currency … [so that] using Bitcoins to purchase goods or services would be treated as a form of barter transaction” still hold, or (given that the definition of “money” is not restricted to the listed items and includes “money”) does CRA consider the purchase and sale of crypto-currencies to be an exempt supply of a financial service (specifically, of money)? ...

CRA, considered this suggestion to be quite at odds with the scheme of the SAM formula rules, which required the SLFI to compute and remit an amount which was quite distinct from the tax paid to its suppliers. ...

Finance has considered: Whether a GAAR penalty should be introduced (the potential downside is that this might have a deleterious effect on the jurisprudence, i.e., fewer Crown wins) Explicitly incorporating economic substance into GAAR. ...

A taxpayer with large unexplained tax reserves may be considered to be at a higher risk of non-compliance. ...

The relevant International Advisory Services Section Manager of the International Tax Division must be consulted in all cases where an audit agreement is being considered for a transfer pricing issue. ...

. … On completion of Section D, the supplier is no longer considered to have made an election in respect of any supplies of memberships as of the effective date of the revocation. ...