CRA offers streamlined procedure for validating historical GST/HST s. 156 (nil consideration) elections

Since January 1, 2015, group registrants wishing to make an ETA s. 156 election for qualifying supplies between them to be made at deemed nil consideration have been required to file their elections with CRA rather than merely signing them and keeping them on hand. In the case of elections which were made in the old (unfiled) way before January 1, 2015, there is a requirement to file a new election form (on RC4016) with CRA by January 1, 2016.

In order to permit group members to avoid multiple filings, CRA is offering a streamlined procedure under which group members that have existing elections with differing effective dates now only need to file one Form RC4616 indicating December 31, 2014 as the effective date – with CRA effectively ignoring this date provided that the old election forms showing the actual earlier effective dates are retained on file by them.

CRA also has changed its services standard, from responding to GST/HST ruling or interpretation requests (that are not highly technical or precedent–setting) within 45 days of receipt, to so responding within 45 days of receiving all relevant facts and supporting documentation.

Neal Armstrong. Summary of Excise and GST/HST News - No. 95 under ETA – s. 156(2).