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.), 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. ...

(c) Have CRA’s collections policies been reviewed in recent months in light of economic conditions, whether in general or in specific industries (such as oil & gas)? ... In the 2013 Federal Budget, the Government provided the CRA additional resources to strengthen the administration of the program. ... (c) Diesel for electricity: Generation of electricity – Secondly, the recovery of excise tax on diesel used to generate electricity has also been significantly restricted. ...

Element C in the s. 6(2) formula appears to contemplate that the cost of the automobile to a person (Holdco) related to the employer is to be taken into account – but 2014-0529991E5 appears to indicate that the leasing cost to Opco should instead be used. ... The formula in subsection 6(2) is worded as follows: A/B × [2% × (C × D) + 2/3 × (E – F)] Element C of this formula represents the cost of the automobile to the employer or to a person related to the employer if either of them owns the vehicle at any time in the year. ... Although the DTS is intended to be a technical resource for income tax service providers, the service is not a problem solving line for a particular taxpayer. ...

c) Would the registrant’s disclosure application be considered as Category 1 – wash transactions (100% penalty and interest relief) or Category 2-general (100% penalty and 50% interest relief) if returns were not filed for 7 years, but all the uncharged HST involved wash transactions? ... Additionally, the requestor should provide a description of the steps, resources and timelines or roadmaps involved in addressing the problems it is facing and the date on which it expects to be able to comply with the legislation. ... Company A will re-supply points to Company B to be issued by Company B to retail customers upon earning points – or to independent dealers to be issued to retail customers of those dealers. ...

Official Response 11 October 2019 APFF Roundtable Q. 5, 2019-0812641C6 F- Professional fees incurred in the context of a litigation with CRA Q.6 Timing of CDA addition on s. 88(1) wind-up Holdco, which has a calendar taxation year-end, commences the winding-up of its wholly-owned subsidiary (Opco – which has a June 30 taxation year-end) on March 31, 2018 with an authorizing resolution, and the Opco assets and liabilities are distributed and assumed on that date. ... (e.2) paragraphs 87(2)(c), (d.1), (e.1), (e.3), (e.42), (g) to (l), (l.21) to (u), (x), (z.1), (z.2), (aa), (cc), (ll), (nn), (pp), (rr) and (tt) to (ww), subsection 87(6) and, subject to section 78, subsection 87(7) apply to the winding-up as if the references in those provisions to (i) “amalgamation” were read as “winding-up”, (ii) “predecessor corporation” were read as “subsidiary”, (iii) “new corporation” were read as “parent”, [...] ... Although DTS is an excellent information resource, the service provides no new interpretations. ...