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If the proceeds of the Loan are used by the beneficiary for personal use such as to buy a personal residence, the Loan would not be considered as a “commercial debt obligation”, so that the definition of the “forgiven amount” would not apply to the settlement of the Loan. ...

Subsection 164(6) – Amending Deceased’s Final T1 Return Subsection 164(6) of the Act (footnote 1) allows capital losses of a graduated rate estate in its first taxation year to be considered capital losses of the deceased, where all required conditions are met. ...

Is the fact of classifying a qualifying non-residential building in a separate class 1(a) or 1(b) sufficient for the taxpayer to be considered to have made the election provided for in subsection 1101(5b.1) ITR.? ...

One (or more) of the members of LP is a corporation resident in Canada (Canco2) that has a sufficient partnership interest in LP such that FA is considered to be a foreign affiliate of that corporation as defined under subsection 95(1) of the Income Tax Act (Act) for the purposes described in subsection 93.1(1.1) of the Act. ...

These will need to be considered and coordinated to ensure the complete and timely filing of the estate’s T3 Trust Income Tax and Information Return (“T3 return”). ...

In light of the SCC Decision, could the CRA confirm whether it is still of the view that Broadcast Rights Payments would be considered as being in respect of a “copyright in respect of the production or reproduction of any literary, musical or artistic work” for purposes of the exception in subparagraph 212(1)(d)(vi)? ...

Although it is not specifically stated above, it is our understanding that the hardware would typically not be considered as “ancillary data processing equipment” considering its significance in most crypto-asset mining operations. ...

In the evaluation of whether subsection 247(2) might apply to adjust an Outbound Charge or an Inbound Charge, all relevant circumstances are to be considered in order to determine the appropriate arm’s length price. ...

What will be considered to be a “reasonable” period of time is a question of fact and will depend upon the particular circumstances. ...

20 June 2023 STEP Roundtable Q. 3, 2023-0968091C6- Trust Reporting – Definition of Money and Treatment of Dividend Receivable Unedited CRA Tags 150(1); 150(1.1); 150(1.2)(b); ITR 204.2 Principal Issues: 1) Whether settlement items such as collectible gold/silver coins and bars would be considered “money” for the purposes of paragraph 150(1.2)(b)? ...