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Clause 6801(a)(iv)(B) of the Regulations provides that where deferred amounts are held by or for the account of any person other than a trust referred to in Clause 6801(a)(iv)(A) of the Regulations, any amount in respect of interest or other additional amounts that may reasonably be considered to have accrued to or for the benefit of the employee to the end of a taxation year must be paid in the year to the employee. ...

Paragraph 5 of Interpretation Bulletin IT-62 states that "While the exemption in the Indian Act refers to "property" and the tax imposed under the Income Tax Act is a tax calculated on the income of a person rather than a tax in respect of his property, it is considered that the intention of the Indian Act is not to tax Indians on income earned on a reserve". ...

Subparagraph 126(7)(c)(iv) excludes from "non-business-income tax" a tax, or the portion of a tax, that would not have been payable had the taxpayer not been a citizen of the country imposing the tax and that cannot reasonably be regarded-as attributable to income from a source outside Canada.      24(l)      We have not previously considered how the determination as to what portion of a foreign tax is reasonably attributable to income from a source outside Canada should be made. ...

It is our opinion that where a Canadian resident becomes a partner in a partnership carrying on business outside of Canada that has never before had a partner who was a resident of Canada, for purposes of determining the Canadian resident partner's share of the income or loss of the partnership for purposes of the Act, the capital cost of the partnership's assets will generally be considered to be the historical cost to the partnership expressed in Canadian dollars utilizing the exchange rate as at the date the partnership acquired the assets. ...

In our opinion, a demand note is an "investment contract" as that term is defined in paragraph 12(11)(a) of the Act and an alteration of a note whereby a non-interest bearing note became interest bearing would be considered material.  ...

(b)     The partnership will continue to be considered the taxpayer which acquired the property or incurred the expenditure for the purposes of subsection 59(3.3) even where all parties who were partners when the property was acquired or the expenditure incurred have ceased to be such. ...

In our opinion, if there is any degree of business it will be considered an "active business" pursuant to the definition found in subsection 248(1) of the Act.  ...

January 14, 2022 David Gagné-Therrien Dedicated Telephone Service, Section I Income Tax Rulings Canada Revenue Agency Directorate David.Gagne-Therrien@cra-arc.gc.ca Kah Foo, Koh 2021-091389 Subject: Canada Emergency Rent Subsidy- Sublease We are writing in response to your recent inquiry wherein you requested our views on whether a document to sublease real property would be considered a written agreement entered into prior to October 9, 2020, as required under the definition of “qualifying rent expense” (“QRE”) in subsection 125.7(1) of the Income Tax Act (the “Act”) for purposes of the Canada Emergency Rent Subsidy (“CERS”). ...

Position Adoptée: Seuls les montants versés en vertu d’une sentence arbitrale peuvent être considérés comme des "montants admissibles" // Only the amounts paid according to the arbitration award can be considered qualifying amounts. ...

For example where a corporation’s statutory filing-due date for its T2 Return falls on a Sunday, the T2 Return will be considered filed on time if it is received on the following day, the Monday. ...