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CRA accepts a tracing approach to determining whether interest on money borrowed to return capital is considered for s. 95(2)(a)(ii)(B) to be deductible in computing exempt earnings

30 May 2016- 1:01am CRA accepts a tracing approach to determining whether interest on money borrowed to return capital is considered for s. 95(2)(a)(ii)(B) to be deductible in computing exempt earnings Email this Content Where FA1 borrows from a sister (FA3) to make a capital distribution on its Class A common shares, which had previously been issued solely to finance FA1’s active business, CRA would accept that the interest on this loan would be received as deemed active business income by FA3 under s. 95(2)(a)(ii)(B). ...

CRA permits professionals who are sharing payroll expenses to jointly open up a single payroll account without being considered to be a partnership

26 March 2017- 9:59pm CRA permits professionals who are sharing payroll expenses to jointly open up a single payroll account without being considered to be a partnership Email this Content A group of dentists, who are not in partnership, wish to share the costs of staff such as receptionists and bookkeepers and also are shared employers of the staff, so that all of the staff remuneration paid by each dentist is exempted from GST/HST as a result of being paid qua employer. ...

Christen – Federal Court finds that a voluntary disclosure planned before, but made after, the audit notification could be considered non-voluntary - but annuls the CRA rejection anyway

3 January 2022- 10:50pm Christen – Federal Court finds that a voluntary disclosure planned before, but made after, the audit notification could be considered non-voluntary- but annuls the CRA rejection anyway Email this Content In May 2015, the plaintiff authorized her law firm to represent her in making a voluntary disclosure of her Swiss assets, and in the summer and fall of 2015, various documents were collected and organized to this end. ...

Louie – Tax Court of Canada places a temporal limitation on the advantages considered to arise from TFSA swap transactions

26 November 2018- 2:04am Louie – Tax Court of Canada places a temporal limitation on the advantages considered to arise from TFSA swap transactions Email this Content From May 15 to October 17, 2009, the taxpayer directed 71 “swaps” under which TSX-listed shares were transferred between her self-directed TFSA and her taxable trading account at a discount brokerage (“TDW”), or between her TFSA and her self-directed registered retirement savings plan (also with TDW). ...

Bowman, "Sophisticated Estate-Planning Techniques: Cross-Border Dimensions", 1993 Conference Report, c. 38: Discussion (at pp.16-17) of whether a Canadian-resident "protector" may cause a trust established outside Canada to be considered to be resident in Canada; and of the weight to be given to the jurisdiction of the governing law of the trust in determining the residence question. -- summary under Subsection 2(1)

Bowman, "Sophisticated Estate-Planning Techniques: Cross-Border Dimensions", 1993 Conference Report, c. 38: Discussion (at pp.16-17) of whether a Canadian-resident "protector" may cause a trust established outside Canada to be considered to be resident in Canada; and of the weight to be given to the jurisdiction of the governing law of the trust in determining the residence question.-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) ...

P-084R "Forgiven Debts Considered Bad Debts" 8 March 1999 -- summary under Subsection 231(1)

P-084R "Forgiven Debts Considered Bad Debts" 8 March 1999-- summary under Subsection 231(1) Summary Under Tax Topics- Excise Tax Act- Section 231- Subsection 231(1) [F]orgiven debts pursuant to an arrangement under the Companies' Creditors Arrangement Act are considered to be bad debts as opposed to reductions of consideration. ...

P-084R "Forgiven Debts Considered Bad Debts" 8 March 1999 -- summary under Subsection 232(2)

P-084R "Forgiven Debts Considered Bad Debts" 8 March 1999-- summary under Subsection 232(2) Summary Under Tax Topics- Excise Tax Act- Section 232- Subsection 232(2) [F]orgiven debts pursuant to an arrangement under the Companies' Creditors Arrangement Act are considered to be bad debts as opposed to reductions of consideration. ...

Certificate of residency "CRA cannot certify the residency of a partnership because partnerships are not considered resident; however, the individual partners of a partnership can ask for a certificate." -- summary under Subsection 2(1)

Certificate of residency "CRA cannot certify the residency of a partnership because partnerships are not considered resident; however, the individual partners of a partnership can ask for a certificate. ...

6 March 1991 External T.I. 9033605 F - Accumulated Vacation Leave - Whether Considered Retiring Allowance

6 March 1991 External T.I. 9033605 F- Accumulated Vacation Leave- Whether Considered Retiring Allowance Unedited CRA Tags 6(3), 248(1) retiring allowance 5-903360 Dear Sirs: Re: Accumulated Vacation Leave Whether considered Retiring Allowance This is in reply to your letter of November 20, 1990 concerning the above-mentioned subject. ... When an employee terminates employment and a payment is made in respect of accumulated vacation leave not taken prior to retirement, the payment of said credits is considered to be ordinary remuneration and is included in the employee's income in the year of receipt pursuant to subsection 6(3) of the Income Tax Act as stated in paragraph 5 of Interpretation Bulletin IT-337R2. ...

5 March 1996 Income Tax Severed Letter 9528801 - WHETHER COMPRESSED GAS CONSIDERED FUEL.

5 March 1996 Income Tax Severed Letter 9528801- WHETHER COMPRESSED GAS CONSIDERED FUEL. ... Reasons: To be considered "Fuel" the gas must be combusted. ... The court held that to be considered "fuel" the gas must be combusted. ...

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