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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. ...

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. ...

Therefore, a payment made by the client to a staffing company would not be considered eligible remuneration paid to an eligible employee of the client. ...

In finding that s. 69(1)(b) could apply to deem the proceeds of disposition on each such sale to be each condominium’s FMV $200,000 on the basis that XYZCo could be considered not to be dealing at arm’s length with each of ACo and BCo, CRA stated: Taking into account that, from the outset, the project was carried out by XYZCo with the objective of building a condominium for each of ACo and BCo, and that, if it were established that Mr. ...

8 November 2021 External T.I. 2021-0882391E5- Acquisition of life insurance policy for ss248(35)-- summary under Subsection 248(35) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(35) whether the conversion of a term to a permanent life policy entails an acquisition for s. 248(35)(b) purposes turns on whether this goes “to the root of the policy” For purposes of counting out the three (or 10) year period under s. 248(35)(b), would a gifted life insurance policy be considered to have been acquired when it was initially issued as a term life insurance policy or at the time it was converted from a term policy to a permanent life insurance policy pursuant to the provisions of the policy? ...

Although the term “company” is “potentially more inclusive than the term corporation” it is considered to refer to a corporation (and would not include a partnership or trust) in the context inter alia of the references in s. 125.7(2.01) to “taxable dividends” and “common shares.” ...

Regarding taxpayers who have elected to use the Quick Method (so that they no longer are entitled to claim ITCs or rebates, but are entitled to remit an amount lower than the actual GST/HST collectible, or collected), “the net gain experienced when using the Quick Method is considered government assistance and included in income under paragraph 12(1)(x).” ...

CRA considered a plan covering all the non-unionized employees of over 1,000 stores in a retail chain, where the benefits offered to the employees varied by participating employer, so that there could be different classes of benefits and coverage levels offered to the employees of the different participating employers. ...