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See Taitz & Millar, ‘‘The GST and National Religious Organizations – Selected Issues”, GST & Commodity Tax (Carswell), Vol. ... Registrants who have spent considerable resources on appraisals, so as to comply with their GST/HST self-assessment obligations, are increasingly frustrated by this approach. ... Why would the CRA spend resources to raise assessments that are at best revenue neutral and at worst put the fisc at risk? ...

We do have more resources than in the past, and we focus particularly on areas of higher risk. ... We had a new communique out to our auditors, which should be on our website fairly soon, that talks about what we call audit agreements – that’s a settlement at audit stage – what’s involved and when we engage that process. ... Written communication is not an effective way to address certain emergent Questions – such as whether particular words or statements under consideration are being taken out of context. ...

The CRA requires that form T2075 be filed twice – this is noted at the top of the form. ... A new resource is available on the Government of Canada website. The T3 electronic filer’s manual (the RC4657) provides supplementary information to taxpayers for the completion and submission of the electronic T3 return using the T3 EFILE service. ... Official Response 15 June 2022 Roundtable, 2022-0924791C6- STEP 2022 – Q18- McNeeley et al v. ...

That’s a 60% increase, from fewer audits, and maybe 5% more in CRA resources. ... Canadian law gives the Minister broad power to compel the production of information – the word “any” is there in the Act – but of course judges have imposed a reasonableness test. ... We are working around in the T1 space – letting taxpayers “load in” their T4. ...

The determination of whether shares of a private corporation, interests in a partnership or interests in a trust are TCP can be complicated because it must be determined if at any time in the previous 60-month period more than 50% of the fair market value of the share or interest was derived directly or indirectly from real or immovable property, Canadian resource properties, timber resource properties and options or interests in these properties. ... In the situation described above, will CRA consider that UKco has a permanent establishment in Canada under Article 5 of the Canada – U.K. ... ASIC Miners ASIC miners, on the other hand, are designed and optimised to perform a single task – mine crypto-assets. ...

We are optimistic that that can save time and resources, both on our side and the taxpayer’s. ... Brault: The document is in final stages of approval – it should hopefully be ready in weeks rather than months. ... There is quite a number of applications – over 2 million if you look period-by-period – so that 100% coverage is infeasible. ...

Q.11(a) Does CRA have IT troubleshooting resources for advisors to help address these issues, beyond calling general enquiries to restore access removed by CRA? ... To assist issuers/filers, the CRA provides several tools and resources to help them meet their obligations in the form of guides and various online tools. ... Process for inital contact – do requests go to taxpayer, representatve, or both? ...

That information can then be used for various purposes, including to better target audit resources, or to provide information that could be useful to Finance. ... In this scenario – where Canada maintains full ability to tax – are the businesses, undertakings and activities of B Co carried on in Canada? ... ATI is determined by the formula A + B – C, and A is determined by the formula D – E. ...

At the 2015 STEP – CRA Roundtable, CRA stated that an individual can only have one estate. ... Anyone wanting to access that Q & A, can go to the CRA website and use the search tool to enter in “graduated rate estate”- and the Q & A will be the first hit for the search. ... Further, the settlor / grantor can exercise his / her power to revoke the trust at any time. ...

.), substantially for the reasons offered in the T.C.C. judgment (" Alco Dispensing ")], M.N.R. v. ... " The “ Dictionnaire de la comptabilité et de la gestion financière ” [The Dictionary of Accounting and Financial Management] provides a specialized definition of "actif" ["asset"] and "éléments d’actifs" ["asset items"] as follows: "A component of the balance sheet that describes the economic resources over which entities have control as a result of past transactions or events, and which are expected to provide future economic benefits to the entity. ... In a self‑assessing tax system such as that provided for in the Act, taxpayers should have confidence that the Minister is administering and enforcing the same tax laws in the same way for everyone (pp. 33-34 and 68). [26] Practically, this constrains the Minister to assess a taxpayer in accordance with the facts of the matter ⸺ here, the transactions ⸺ and the law (CIBC World Markets Inc. v. ...