CRA will no longer unilaterally issue backdated GST/HST registrations

New ETA s. 241(1.5) permits CRA to unilaterally assign a registration to a taxpayer, if it has first notified the taxpayer that the taxpayer should register. However, it cannot backdate the registration.

CRA appears to have acknowledged that this means that CRA can no longer follow its previous practice of unilaterally issuing backdated registrations. However, see also CBA RT Q.23, where CRA stated:

If the CRA exercises the authority under subsection 241(1.5)…to register a particular person, the CRA could still assess that person under paragraph 296(1)(a)…for unremitted net tax in respect of reporting periods prior to that person’s effective registration date.

Neal Armstrong. Summary of May 2016 Alberta CPA Roundtable, GST Q.10 under ETA s. 241(1.5).