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Reasons: Update provided by the Appeals Branch. 2018 CTF Annual Conference CRA Roundtable Question 6 – Appeal Process Update CRA published several commitments to improve the appeal process as part of the December 2016 Auditor General Report. ... The Agency has added resources to address the workload of high-complexity objections. ...

15 November 2016 Roundtable, 2016-0672321C6- Guidance on determination of safe income Unedited CRA Tags 55(2), 55(5)(b), 55(5)(c), 152(2), 163(2), 239(1) Principal Issues: Various questions raised regarding the calculation of safe income- see document Position: see document Reasons: see document TEI – CRA Liaison Meeting – November 15, 2016 Question B3: Subsection 55(2) guidance on determination of safe income a. ... As it stands now, when a taxpayer makes a request to the CRA to obtain a copy of income tax returns and/or notices of assessment, the CRA will attempt, in regards to available resources, to provide the requested documentation. ...

Canadian Tax Foundation National Conference 2011 November 27 – 29, 2011 ROUNDTABLE QUESTION # 13 Q.13. ... Among the publications that emerged as the most in demand were those related to: the medical expense tax credit, education and tuition tax credits, along with scholarships and bursaries, interest deductibility, foreign exchange gains and losses, legal and accounting fees, health and welfare trusts, determining residency, residence of a trust, employee stock options and damages & settlements. ... Income Tax Folios will be a valuable resource for years to come. Renée Shields 2011-042629 ...

The approach allows the CRA to focus its audit resources on the highest-risk cases of non-compliance within the large business population, and reduce the compliance burden for businesses that are considered low risk. ... Those taxpayers that are considered high risk per the work plan will be selected for a full compliance audit starting at the Tier III – Risk Assessment and Validation stage. ... The CRA will communicate to the taxpayer the significant tax audit issues in the case and the reasons for assigning more resources if applicable. ...

In its letter dated October 9, 1998, the Partnership states that “all of the current members of this partnership are corporations and have been since XXXXXXXXXX ” and that the individuals involved are “all former retired partners who still have a residual capital balance owing to them” as described in section 98.1 of the Income Tax Act (the “Act”). ... We hope this will be of assistance. for Director Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Directorate Policy and Legislation Branch ...

The determination of whether a payment plan includes income from property is a question of fact. 2012 Ontario CTF Conference – October 30, 2012 CRA Roundtable Question 16 Distinction between income from property and income earned in a business by a non-profit organization (NPO) for purposes of ss 149(5). ... In Interpretation Bulletin 83R3, Non-profit organizations – Taxation of income from property, CRA has also take the position that rental income can be income from property or income from business, depending upon whether the rents were derived from one of the main activities of the club or ancillary to the activities of the club. ... The question seeks CRA's guidance in respect of the characterization of income earned from various types of possible payment plans in respect of membership fees, monthly dues and fees for the use of club resources. ...

Our opinion is based on the fact that the presumptions under paragraph 251(5)(b) and under paragraph 256(1.4)(a) are different, in that, under paragraph 251(5)(b), "... the person shall,..., be deemed to have the same position in relation to the control of the corporation as if the person owned the shares..." and, under paragraph 256(1.4)(a), "... the person or partnership shall,..., be deemed to own the shares at that time, and the shares shall be deemed to be issued and outstanding at that time; " In the situation described above, the application of paragraph 251(5)(b) results in shareholder B, the public corporation, controlling the subsidiary, and, therefore, the subsidiary not being a CCPC, as defined under subsection 125(7). ... Author: Marc LeBlond Corporate Reorganizations and Resources Division Phone Number: 946-3261 Tracking ID: 2003-004857 ...

In Interpretation Bulletin 83R3, Non-profit organizations – Taxation of income from property, CRA has also take the position that rental income can be income from property or income from business, depending upon whether the rents were derived from one of the main activities of the club or ancillary to the activities of the club. ... The purpose of our question is to seek further guidance as to CRA's assessing position in respect of the characterization of income earned from various types of payment plans offered by clubs in respect of membership entrance fees, monthly dues, and fees for the use of club resources (collectively referred to hereinafter as the "Fees"). ... The question seeks CRA's guidance in respect of the characterization of income earned from various types of possible payment plans in respect of membership fees, monthly dues and fees for the use of club resources. ...

Ainsi, la SEEP peut renoncer en faveur de l'investisseur initial à certains frais d'exploration au Canada (« FEC ») et aussi aux frais d'aménagement au Canada (« FAC »). ... Les FAC renoncés par la SEEP sont ajoutés au compte des frais cumulatifs d'aménagement au Canada (« FCAC ») et peuvent être déduits jusqu'à un maximum de 30% du solde disponible. ... En contrepartie et afin de refléter ces nombreux avantages fiscaux, le prix de base rajusté (« PBR ») de l'action de SEEP est réputé nul. ...

Lors de la Table ronde de 2004 du congrès de l'APFF, l'ARC a exprimé sa position vis-à-vis une transaction visant la disposition partielle d'actions d'une société opérante (" OPCO ") en faveur d'une nouvelle société (" EMPLOYÉCO ") détenue par des employés-clés. ... Monsieur X souscrit à 65 % des actions ordinaires d'OPCO, tandis qu'EMPLOYÉCO souscrit à 35 % des actions ordinaires d'OPCO. ... The CRA had noted the fact that EMPLOYEECO did not have the financial resources enabling it to acquire the shares it held from Mr. ...