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Voluntary disclosure – tax services offices CRA Comments Q.6. Voluntary disclosures – 10 YEAR RULE CRA Comments Q.7. ... Natural resource royalties CRA Comments Q.38. Medical care services CRA Comments Q.39. ... Natural resource royalties Summary of Question Pursuant to s. 162(2) of the ETA, a supply of certain natural resource rights is deemed not to be a supply and therefore GST does not apply on any consideration payable for the supply of the right. ...

Email this Content 21 November 2017 CTF Annual Conference Roundtable Q.1 – S. 107(2) distribution by resident trust to Canco owned by non-resident Preliminary response Official response Q.2 – Trusts and principal residence exemption Preliminary response Official response Q.3 – S. 55(2.1) “purpose” CRA response- Background Q.3(a) Purpose v. result Preliminary response Q.3(b) Objective v. subjective Preliminary response Official response Q.4 – S. 55(2) – Timing of deemed capital gain Q.4(a) Timing of gain Q.4(b) CDA Preliminary response Official response Q.5 – Interaction of ss. 55(5)(f) and 55(2.3) with s. 55(2.1) Q.5(a) Separate test Preliminary response Q.5(b) Stock dividend Preliminary response Official response Q.6 – Circular Pt. ... The determination of which Bulletin should be updated was based on the feedback from internal and external stakeholders, and on the availability of resources. ... Given the number of businesses in our data base, it would be very time- and resource-intensive to validate the delegate information process with each registrant. ...

Email this Content 2020 IFA-YIN Seminar on COVID-19 Guidelines Q.1 — Whether "Travel Restrictions" Must Be Enforceable Q.2 — Meaning of "Solely as a Result" Q.3 — Individual Not Ordinarily Resident in Canada Q.4 — Non-Resident Employers Q.5 — Directors Forced to Stay in Canada Q.6 — Location of Board Meetings Q.7 — Applicability to Residence in Other Jurisdictions Q.8 — Competent Authority Tie-Breaker Rule Q.9 — Non-Treaty Countries Q.10 — Non-resident corporation's return obligation Q.11 — S. 253(b) test during COVID Q.12 — TPM-17 and COVID government assistance Q.13 — Contacting CRA Q.14 — Waiver and Clearance Certificates Q.15 — CEWS and bad debts/discounts Q.16 — Convertible debentures Q.17 — Cameco This summarizes CRA responses at a webinar hosted by the International Fiscal Association (Canadian Branch) on 6 August 2020 (a Young Members Event). ... Gallivan: CRA doesn’t have infinite resources. You should be alive to the concept of materiality. ... Q.16 — Convertible debentures Is there any update on the CRA’s administrative position on convertible debt as expressed in 2013-0509061C6 Part XIII Tax & Standard Convertible Debentures? ...

In Scenario 1, the exchange rate of the US dollar is US $1 = CDN $1 at Time 1 and US $1 = CDN $1.2 at Time 2 At Time 2 Can Opco pays a dividend of $120 to Can Holdco In Scenario 2, the exchange rate of the US dollar is US $1 = CDN $1.2 at Time 1 and US $1 = CDN $1 at Time 2 At Time 2 Can Opco pays a dividend of $100 to Can Holdco. ... The property identified by s. 128.1(4) comprises real or immovable property situated in Canada, Canadian resource property, timber resource property, Class 14.1 property that are used in a business carried on in Canada, and an excluded right or interest as defined under s. 128.1(10). ... This implies a degree of correlation or direct substitution – one might say a “causal relationship” – between the disposition of the former property and the acquisition of the new one. ...

The Income Tax Audit Manual (ITAM) serves as the primary resource for instructing auditors on evaluating audit-based evidence. ... These resources are regularly reviewed, redesigned and/or updated as required, when legislative changes occur. ... Q.19(b)- Time for “T” slips to appear in My Account / Represent a Client Members have noted long delays for slips to appear on My Account / Represent a Client. ...

Tax on Split Income – Excluded Shares CRA Response Q6. Tax on Split Income – Business Sale CRA Response Q7. ... RC4188 – What you should know about audits, and IC98-1R7 – Tax Collections Policies. ... CRA Response We had been experiencing high volumes of late-filed elections and added additional resources to address the back log in the Fall of 2018. ...

They also have resource officers available to assist them on more complex issues. ... We are actively addressing the delay and allocating additional resources to this area as we strive to return to our usual service standards. ... These are generally reversed after contact with CRA, but result in professional fees, delayed clearance time and expended CRA resources. ...

Email this Content 17 May 2023 IFA Roundtable Q.1 – Cross-border charges re stock-based compensation Preliminary Response Q.2 – Ukraine/Russia reporting requirements Preliminary Response Q.3 – T1134 disclosure of dividends Preliminary Response Q.4 “Special tax benefit” exclusion under Barbados Treaty Preliminary Response Q.5 – Canadian home offices and US employers Preliminary Response Q.6- Art. ... Where goods are produced or services are performed – again, this will be affected by the nature of the individual’s activities and USco’s business will be relevant in weighing this factor. ... For example, a Canadian accountant preparing the financial reporting for USco, might not constitute USco carrying on business in Canada, nor might a human resource professional who provides internal support to USco’s managers. ...

HST place of supply rules – legal services CRA Comments Q.25. HST place of supply rules – sales of tangible personal property CRA Comments Q.26. ... We continue to invest additional resources to mitigate the risks associated with the increasing inventory of objections. ... Summary of Facts A supplier (“ Québec Co. ”) manufactures widgets for its customer (“ Ontario Co. ”). ...

A3 CRA reorg, large case audits, resource allocation CRA Response- 3a, 3b (large case/aggressive) CRA Response- 3c (resource allocation) B. ... CRA Response- 3c (resource allocation) In response to your question on the bases of allocating resources and technical capacity; as much as possible resources and specific specialties are located close to the large file taxpayer population. ... D4- Provincial allocation disputes At one time, the CRA employed a formal process — the Tax Re-Allocation Committee (TRAC) — for resolving provincial allocation disputes. ...