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. … If the[re] is considered to be one failure, the taxpayer would only be liable to a maximum penalty of $100 under subsection 162(5) for failing to provide information. ...

CRA indicated that, even in this specialized context, it considers that a limited or general partner has a PE wherever the partnership has a PE, so that the reinsurer in question was considered for Reg. 403 purposes to have a PE in various provinces by virtue of being a partner- even though the partnership in question did not carry on any insurance business. ...

Headquarters responded: [G]iven that subsection 189(1) of the Act and subsection 188.1(4) of the Act apply to different parties, each of these provisions must be considered independently of each other. ...

The TSO considered that the beneficiaries of Trust 2 and Trust 3 were not entitled to the capital gains deduction under s. 110.6(2.1) based on 2016-0667361E5. ...

In that case, if s. 12(1)(x) rather than s. 9 is considered to govern, there is a deemed receipt of government assistance on that date, so that the s. 12(1)(x) inclusion will fall into the subsequent taxation year. ...

17 May 2021 Internal T.I. 2020-0870041I7- CERS- Meaning of Qualifying Property-- summary under Qualifying Property Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Qualifying Property a property can be bifurcated into a qualifying property and a residence for CERS purposes Regarding queries as to whether the determination of a property as a qualifying property for Canada emergency rent subsidy (“CERS”) purposes depends on its legal title, and whether a property containing a self-contained domestic establishment (“SCDE”) can be a qualifying property, CRA indicated: Regarding the reference in the “qualifying property” definition to “real or immovable property, in the common-law provinces, the term “real property” is “generally considered to mean land and anything growing on, attached to, or erected on it, excluding anything that may be severed without injury to the land.” ...

Accordingly … business interruption insurance proceeds would generally be included in qualifying revenue and would generally not be considered an extraordinary item. ...

(f) of the “public health restriction” definition, and the test of whether “restricted activities” at the office had ceased, CRA stated: [I]n the case of a travel agency, if, prior to the closure, clients made in-person visits to the office to arrange travel bookings and in-person visits ceased upon closure of the office as a result of an order or decision, then those activities could be considered restricted activities and this condition could be satisfied. ...

CRA stated: … [I]t appears that the requirements to use the rule in paragraph 125.7(4)(d) could be met since all of Opco’s revenue would be considered to be derived from persons with which Opco does not deal at arm’s length (the participants of the joint venture, Holdco 1 and Holdco 2). ...

It then indicated that it considered that it was within the IRS’s jurisdiction and not its jurisdiction to determine whether the trust is eligible to elect pursuant to Art. ...