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Email this Content 2022 Alberta CPA Roundtable Q.1- Dealing with CRA on Assessments and Reassessments Q.1(a) CRA Comments Q.1(b) CRA Comments Q.1(c) CRA Comments Q.1(d) & (c) CRA Comments 2. ... Q.1(d) & (c) d) What is the best approach to resolve these issues? ... Response d) & e): CRA Comments Providing all the supporting documentation and clearly indicating the fields to adjust could help prevent issues with the requested reassessment. ...

For more information about how to obtain an advance income tax ruling or technical interpretation from the Income Tax Rulings Directorate, see the CRA’s Information Circular IC70-6R11, Advance Income Tax Rulings and Technical Interpretations³. ¹ GOVERNMENT OF CANADA, Dedicated telephone service for income tax service providers: How to register, (online: https://www.canada.ca/en/revenue-agency/services/tax/tax-professionals/dedicated-telephone-service.html) ² GOVERNMENT OF CANADA, Contact the Canada Revenue Agency (online: https://www.canada.ca/en/revenueagency/corporate/contact-information.html) ³ GOVERNMENT OF CANADA, IC70-6R11 Advance Income Tax Rulings and Technical Interpretations (online: https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/ic70-6/ic70-6-advance-income-tax-rulings-and-technicalinterpretations.html) GST – AUDIT Question Type: Admin/Process Question The legislation is very clear in section 296 of the ETA that the Minster shall assess allowable credits as part of net tax when these are discovered, both ITCs and rebates. ... PROCESSING DELAYS Question Type: Admin/Process Question What is causing the delays in processing slips in the My Account / RAC system? ... The possible answers seem to be: (a) The AII will be available on the entire cost of the asset on its completion – it is considered “acquired” in its entirety only when it is completed (b) The AII will not be available if construction of the asset commenced prior to November 21, 2018 – it was considered “acquired” when construction commenced. ...

Q4 Voluntary Disclosure – “One Year” Rule Etc. Facts/Background A Co., a GST non-registrant, purchases a residential complex in January 2007. ... In that case, the assessments were issued on letterhead from Revenue Canada – Taxation rather than the Department of National Revenue and had the printed signature of a person who was no longer the Deputy Minister. ... The Notices of Reassessment issued since April 1, 2007 are made up of a “Results” page and one or more “Summary of (Re) Assessment “ pages. ...

An overview of the relevant facts can be illustrated as follows: Beginning End ──────────────────────────────────── ──────────────────────────────────── ┌───────┐ ┌────────┐ ┌────────┐ ┌────────┐ ┌────────┐ ┌────────┐ │Partner│ │Partner │ │Partner │ │ │ │Partner │ │Partner │ │ A │ │ B │ │ C │ │ A │ │ B │ │ C │ └───┬───┘ └───┬────┘ └───┬────┘ └────────┘ └────┬───┘ └───┬────┘ │ │ │ │ │ │ │ │ │ │ │ │ │ │ │ │ │ │ │ │ └────┬─────┴───────┬──┘ ┌─────┴─────────┤ │Partnership I│ │Partnership II │ │ Assets │ │ Assets │ └─────────────┘ └───────────────┘ We assume that any wind-up of Partnership I would be effected on a tax-deferred basis for the purposes of the Income Tax Act. ... Q.22- Section 156 Election Can Canco #1 and Canco #2 enter into the section 156 election under the following corporate structure: ┌─────────┐ │ │ │ U.S. │ ┌────┴─────────┴────┐ │ │ 100%│ │100% │ │ ┌────┴────┐ ┌────┴────┐ │ │ │ │ │ U.S. #1 │ │ U.S. #2 │ └────┬────┘ └────┬────┘ │ │ 100%│ │100% │ │ ┌────┴────┐ ┌────┴────┐ │ │ │ │ │Canco #1 │ │Canco #2 │ └─────────┘ └─────────┘ Assume that: (i)Canco #1 and Canco #2 are corporations resident in Canada and are registered for GST; (ii)U.S., U.S. #1 and U.S. #2 are non-residents of Canada and are not registered for GST. ... If so, how can this position be reconciled with the Carlson & Associates Advertising Ltd., [1998] G.S.T.C. 25 decision? ...

Q.2b – CRA guidance on PPT Lori Carruthers: Given that each situation is likely to be unique, we again recommend Advance Income Tax Ruling as the best source of certainty. ... Q.2c – Expedited rulings Lori Carruthers: No, we will not commit to an expedited basis, although we are sensitive to the need for all taxpayers to receive a response to a ruling request as quickly as possible, and we are working towards that. ... CRA will consider a request for relief in the form of extensions and waivers of penalties on a case-by-case basis – although I would expect that the Minister will require more than “they just shortened the deadline from 15 to six months!” ...

Part 1 – Child group indirectly owns purchaser corporation “Can the child group own the purchaser corporation through on ore more holding companies owned by them?” ... Part 2 – Purchaser corporation held beneficially by child group “Can shares of the purchaser corporation be held by a trust under which the only beneficiaries are members of the child group?” ... Part 3 – Child group are trustees “Can shares of a purchaser corporation be held by a trust if the trustees are all members of the child group and the parents are not beneficiaries?” ...

Official Response 15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F- IFA 2020 Roundtable – T2057 & Functional Currency Q.2- Withholding if swap mismatches A Canadian resident taxpayer (Canco) enters into a Swap Agreement (Swap Agreement) with a non-arm’s length non-resident company (NRco). ... This is where the wage subsidy – we’ll say $10 in this case – would be taken into account. ... Subpara (ii) describes other circumstances where distributions can be traced to the initial investment – in this case, the shares of FA1. ...

D & D Livestock What is the CRA's position regarding [D & D Livestock] which allowed a taxpayer to take into account twice the amount of the "safe income" in the context of subsection 55(2) of the ITA? ... The advance rulings consultation process started slowly – only 6 or 7 in the first 9 months. In the last 3 months there were 21 files – 17 of them concluded. In 9 of them the taxpayers were told “no way.” ...

Of particular relevance to this specific question is the definition of “advantage” in 207.01(1) – advantage- (b)(i). ... They are the main sources of referrals to the Committee – although the Committee also considers advance income tax ruling requests on the GAAR. ... LLC that is a foreign affiliate and has a single member which is a regarded U.S. corporation should compute its “earnings” in accordance with Reg. 5907(1) – earnings- s. ...

Of course, disputes will still happen – just look at the Trump tax-reforms in the US. ... It’s the same thing with the litigators – it’s something that auditor teams can have on request. ... Michael O’Connor – Does that include drafts of working papers? Gord Parr – Generally the final documents will suffice. ...