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CRA further announced in 2020-0846751E5: In these extraordinary [COVID] circumstances, a HCSA that qualifies as a PHSP and which has unused credits expiring between March 15 and December 31, 2020, could temporarily permit the carry forward of those unused credits for a … period of up to six months [which] would generally be considered reasonable and would not, in and of itself, disqualify the HCSA from being a PHSP. ...

. … [A]ll of the facts and circumstances surrounding a FTS offering would need to be considered in detail before concluding whether a particular share issued under that FTS offering is a prescribed share …. ...

Stage 2: An allowance to recognize ECLs for loans for which there have been significant increases in credit risk since initial recognition and the credit risk is not considered low. ...

4 January 2022 External T.I. 2015-0607531E5 F- Action admissible de petite entreprise-- summary under Subparagraph 110.6(14)(f)(i) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(14)- Paragraph 110.6(14)(f)- Subparagraph 110.6(14)(f)(i) s. 110.6(14)(f)(i) can apply to an amalgamation S. 110.6(14)(f)(i) provides that, for purposes of the requirement in s. 110.6(1)(b) that mooted qualified small business corporation shares ("QSBCSs") must not have not been owned during the 24 months preceding their disposition (the “determination time”) by anyone other than the disposing individual or a related person or partnership, such shares will be considered to have been so owned prior to their issuance by a “bad” owner unless they were issued as consideration for other shares (the “original shares”). ...

CRA considered such loss of the safe harbour to be anomalous, and had notified Finance accordingly. ...

CRA went on to state: Where in a particular year, more than 50% of a particular property is being used for some purpose other than farming or fishing or is otherwise vacant or idle, generally speaking, such non-farming or fishing use would result in the entire property not being considered as being used principally in the business of farming or fishing in Canada for the year. ...

7 March 2022 External T.I. 2021-0895571E5- Clarification of Comments in 2020-086483-- summary under Paragraph (k) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement- Paragraph (k) 3 years may start counting from before the grant year/ unfavourable counting where employer has non-calendar year 2020-0864831I7 found that full-value restricted share units (“RSUs”) granted early in the calendar taxation year of the employer (the “Grant Year”) were considered to be in respect of services in the previous year, so that such award came within the salary deferral arrangement (SDA) definition, and would not be excluded under para. ...

Although the Directorate indicated that one possible interpretation would require the associated CCPCs to convert each component of their TCEC computation (which the Directorate noted “would be administratively burdensome, especially when the associated corporations could not rely on subsection 261(7)”), the Directorate concluded: The day the TCEC of the associated corporation is considered to “arise” for the purposes of determining the conversion rate according to paragraph 261(5)(c) is the last day of the taxation year of the associated corporation for which it is computed because that is the day when the amount of the TCEC is determined pursuant to section 181.2 (hence when an amount relevant to computing the Taxpayer’s Canadian tax results is created). ...

Here, since Canco directly owned 100% of a non-resident corporation (Nrco1), and indirectly owned 100% of each of the other two non-resident corporations (Nrco2 and Nrco3), through Nrco1, Canco would be considered the lowest-tier corporation in the group of taxpayers resident in Canada. ...

If the employee worked in Canada but the employment duties required significant time in another country, an apportionment of the individual’s salary or wages based on the number of working days spent in Canada and in that other country is (per Folio S5-F2-C1) usually considered appropriate in determining the amount of foreign-source employment income for the purpose of the foreign tax credit calculation. ...