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CRA responded: Where a building (or other structure) is being erected by or for a taxpayer on land owned by the taxpayer, they are considered to have acquired a building (or other structure), at any particular time, to the extent of: the construction costs incurred by the taxpayer to that time, including the cost to the taxpayer of materials that have been put in place, but not including holdbacks that constitute a conditional liability (for example, a holdback which requires that the work be approved by the taxpayer’s architect or engineer before payment), or progress billings received by the taxpayer to that time, net of any holdbacks that constitute a conditional liability. ...

If the loan is considered received because of shareholdings, the [exempting] CRA administrative policy does not apply. ...

Since the supplier simply contacts the common carrier to inform them that the good is ready for pick up, the supplier is not considered to have retained the carrier on behalf of the recipient. ...

For example, one of the results of making the election is that the units of the series held by a non-resident person that is an individual or specified investor, or units of an exchange-traded series held by a non-resident person would not be deemed to be held by an individual resident in Canada that is not resident in any participating province for the purpose of the SLFI Regulations and would continue to be considered units held by a non-resident of Canada. ...

However, if an employer is interested in participating, the amount paid by the employer will be considered as a taxable benefit to the employee and included on the employee's T4 as income. ...

P-099 "The Meaning of 'Hotel', 'Motel', 'Inn', 'Boarding House', 'Lodging House' and 'Other Similar Premises', as used in the definition of 'Residential Complex' and 'Residential Unit'" 16 December 1993-- summary under Residential Complex Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Residential Complex The determination of whether an establishment is a hotel, motel, inn, boarding house, lodging house or other similar premise, should be based on...all the following guidelines.... the establishment normally provides temporary accommodation rather than a permanent place of residence; where required by municipal and/or provincial regulations, the establishment is licensed for business for the purpose of providing a temporary place to stay; the establishment is available for rental to the public on a temporary [transient] basis [For this purpose, the public is considered to be either the community as a whole or a defined class of the public, such as students or senior citizens. ...

Imposing such penalty would only occur in the context of a compliance action, such as an audit, where all factors and circumstances of the taxpayer’s particular situation are considered together. ...

CRA indicated that “[t]he acknowledgment of an electronically filed return is issued in Eastern Time” but that (in the case of an April 30 filing deadline) “a return will be considered filed on time if the CRA receives it on or before April 30 in the respective Canadian time zone.” ...

In this regard, CRA noted its position that, in the absence of evidence to the contrary, it considered there to be a presumption that all the trustees would constitute a group, so that generally all such trustees would need to be members of the child group. ...

CRA indicated that, to ensure that the trust account number for the bare trust is no longer considered active or open, the trustee may: (i) send a letter to the trust tax centre indicating that the bare trust has ceased to exist, and providing the trust account number, the bare trust name and the date on which it ceased to exist; or (ii) file a final T3 return for the 2024 tax year with the date on which the bare trust ceased to exist. ...