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ARTICLE · 20 OCTOBER 2020

Mini CEWS Update: Cost-Sharing Arrangements And CRA Audits

A detailed review of the Canada Emergency Wage Subsidy ("CEWS") can be found in our updated detailed review of the Federal Economic Measures here.

CanadaAccounting and Audit

A detailed review of the Canada Emergency Wage Subsidy ("CEWS") can be found in our updated detailed review of the Federal Economic Measures here.

However, there have recently been two new announcements that we believe are worth an extra alert.

Cost-sharing arrangements

First, the CRA has finally indicated that the CEWS is available in cost-sharing arrangements ("CSA").

In many CSAs (often used by doctors and other professionals), there is more than one employer since there are several employers in the arrangement to share the payroll costs and, often, an entity (e.g. clinic) is used to split the costs. Prior to the July 2020 changes to CEWS, the employers could not qualify for CEWS because they did not have a payroll account as of March 15, 2020, only the entity/clinic did. However, often the entity/clinic could not show the necessary drop in revenues, even if the corporations sharing costs did have the necessary drop in revenue.

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