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CRA responded We are currently reviewing the extent to which the Medallion decision would affect our position with respect to the issue of who can be considered to be a participant in a joint venture for purposes of section 273 of the ETA, and this includes taking into consideration the issue described in the question. ...

Freelance journalists are generally not considered to be employees of an organization, but would be self-employed contractors. ...

Amalgamated corporations and subsidiaries that are merged into their parent corporation are also considered predecessor employers for purposes of the registered pension plan rules. ...

These requests will be considered on a case-by-case basis. As a condition, Paragraph 4 of policy statement P-255 specifies that all GST/HST returns must be filed by all parties to the election, and, that the parties must be fully compliant with the GST/HST legislation. ...

., the recommendation of the Canadian government that every Canadian return home) or a mandatory quarantine period (imposed by the Canadian government or a foreign government) be considered a “Travel Restriction”? ...

2020 IFA-YIN Seminar on COVID-19 Guidelines, Q.10-- summary under Clause 150(1)(a)(i)(B) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1)- Paragraph 150(1)(a)- Subparagraph 150(1)(a)(i)- Clause 150(1)(a)(i)(B) there generally is no COVID relief from the obligation on non-resident corporations carrying on business Canada to file tax returns In light of OECD commentary that tax administrations should minimize burdensome compliance requirements during the COVID-19, could CRA waive the requirement to file a tax return for non-resident corporations resident in a non-treaty jurisdiction, which are considered to be carrying on a business in Canada only because of COVID Travel Restrictions? ...

Therefore, that wording is usually used in situations where CRA was seriously considering whether a s. 247(3) penalty would apply, but considered that the information before the Committee was insufficient. ...

Admittedly, the CRA might have considered the proposed amendment to represent a change if it had been asked 15 years ago, but the new wording accords with the CRA’s current positions. ...

Reporting of deduction for reorganization gains [Line 342: deduct:] Accounting gain on transfer of property to a corporation under section 85 or 85.1 of the federal Act *** … Note … ***A joint election will be considered made under subsection 60(1) of the Ontario Act if there is an entry on line 342, and an election has been made for transfer of property to a corporation under subsection 85(1) of the federal Act. ...

27 February 2020 CBA Roundtable, Q.14-- summary under Subsection 298(7) Summary Under Tax Topics- Excise Tax Act- Section 298- Subsection 298(7) CRA is considering whether a GST/HST waiver can be restricted to a specific issue The questioner encountered a considered CRA audit position that, since no provision allows CRA to assess, in its audit of taxable and exempt supplies made by a registered supplier, for anything other than the net tax collectible by the supplier, it would not be permissible for the supplier to limit a waiver to whether a particular supply was exempt or taxable – instead, the “matter” at issue must be regarded as the entire net tax calculation for the reporting period, so that the waiver cannot be limited to something less than this. ...