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A carry-forward period of up to six months would generally be considered reasonable and would not, in and of itself, disqualify the HCSA from being a PHSP. ...

13 March 2020 External T.I. 2019-0833181E5- TOSI- Excluded Shares-- summary under Subparagraph (a)(i) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares- Paragraph (a)- Subparagraph (a)(i) the sale of digital content generates gross income from property rather than services for TOSI purposes Is the income of a corporation that produces and “sells” training videos as digital downloads from its website to be considered as income from the provision of services for the purposes of (a)(i) of the “excluded share” definition? ...

In finding that Aco qualified as a prescribed person described in Reg. 4802(1)(e), CRA stated: By virtue of the Deemed Ownership Provision … that deems the Crown to own all of Aco’s property, the Crown would be considered to own any shares of Invesco acquired by Aco. ...

[W]here two or more joint owners of a share of a corporation are considered one shareholder under relevant corporate law or are entitled to jointly receive any dividend paid on the share by the corporation, the joint owners of the share will generally be counted as one shareholder for purposes of paragraph 130.1(6)(d) of the Act. ...

In finding that s. 7(3)(b) prohibited EmployerCo from claiming a deduction for this payment in computing its income, CRA stated: [A] portion of the rights of the employee under the RSU Plan is considered to have been disposed of by the employee in exchange for EmployerCo paying the required income tax withholdings arising from the issuance of shares of ParentCo under the RSU Plan. ...

In this context, would the Corporation be considered to have limited its activities as required by s. 149(1)(o.2)(ii)(A). ...

Unless the Payments were considered qualifying revenue, the Contractors would qualify for the CEWS – but if they receive it, the Operator will reduce future amounts paid by a corresponding amount. ...

Unless the Payments were considered qualifying revenue, the Contractors would qualify for the CEWS. ...

The gift of the equitable interest in the CRT is considered to have been made to the qualified donee when the property is transferred to the CRT, provided that the equitable interest in the CRT vests with the qualified donee at that time (and all other requirements are met). ...

If … the addition of interest to the principal … qualifies as a novation … the amount of interest will be considered paid when the novation occurs and will be eligible for the credit by virtue of section 118.62, if all the conditions set out in that section are otherwise satisfied. ...