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CRA stated: Generally, costs associated with the purchase and installation of renewable energy property eligible for the FIT/microFIT Programs are considered to be the capital cost of depreciable property. ...

3 April 2020 External T.I. 2019-0830101E5- “Advantage”: promotional incentive exception-- summary under Premium Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(1)- Premium referral bonus is considered to be a premium contributed to the plan In indicating that it will consider a referral bonus paid into a registered plan to be a contribution to the plan, CRA stated: While referral bonuses may be commercially reasonable, they are not offered to compensate investors for the use of their money as is a typical return on investment. ...

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. ...

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. ...