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. … Official Response 16 June 2014 STEP Roundtable, Q. 3, 2014-0522971C6 See summary under 93.3. ... The initiative also required all paid preparers of individual income tax returns who are not CPAs, attorneys or enrolled agents to pass a competency exam and complete annual continuing education requirements related to tax law and professional conduct. … [I]n January 2013… the U.S. ... By registering tax preparers, the CRA will be able to fulfill the goal of the RTPP – to identify which tax preparers are making errors and to work with them to prevent these errors before the tax return is filed. ...

The preamble to s. 104(4) states that the deemed disposition dates apply to each property of the trust – that is, the dates are not tied to specific properties. S. 104 might not apply in the circumstance, because s. 108(1) – “trust” – (g) generally provides that the s. 104(4) will not apply to a trust in which all interests have vested indefeasibly. ... The result is the same as it was in the first scenario for the person who is just the shareholder in that s. 15(1.4)(c) won’t apply, for the same reason – the amount of the wages are already included in the shareholder’s income – in this case, the shareholder-employee’s employment income. ...

Therefore using Bitcoins to purchase goods or services would be treated as a form of barter transaction ….” ... Under s. 225.2(2), the SLFI is required to determine its net tax under the formula [(A-B) x C x (D/E)]- F + G (SAM Formula). ... S. 228(2.3) provides that “where a person who is a [SLFI] is required to file a final return … (a) the person shall calculate … the net tax … (b) where the net tax of the person… is a positive amount, the person shall remit that amount to the Receiver General on or before the day the final return for the reporting period is required to be filed.” ...

.), substantially for the reasons offered in the T.C.C. judgment (" Alco Dispensing ")], M.N.R. v. ... The Petit Robert de la langue française defines the term "actif" [“asset”] as “l’ensemble des biens ou droits constituant le patrimoine “ ["all the property or rights constituting the patrimony"]. ... 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. ...

However it is not clear that this is still the practice under the new voluntary disclosure program, since disclosure officers say they now just make their relief decisions, the returns submitted with the disclosure are then sent “for processing” – and they don’t know how processing is handled. ... 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? ... 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. ...

(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)? ... Does CRA concur that the amount of Variable C would be nil – that is, that losses realized and not utilized in the immediately preceding year are not considered in the computation of an opening LRIP balance? ... (c) Diesel for electricity: Generation of electricity – Secondly, the recovery of excise tax on diesel used to generate electricity has also been significantly restricted. ...

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. ... Paragraph 88(1)(e.2) reads as follows: Winding-up 88 (1) Where a taxable Canadian corporation (in this subsection referred to as the “subsidiary”) has been wound up after May 6, 1974 and not less than 90% of the issued shares of each class of the capital stock of the subsidiary were, immediately before the winding-up, owned by another taxable Canadian corporation (in this subsection referred to as the “parent”) and all of the shares of the subsidiary that were not owned by the parent immediately before the winding-up were owned at that time by persons with whom the parent was dealing at arm’s length, notwithstanding any other provision of this Act other than subsection 69(11), the following rules apply: [...] (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”, [...] ...

S. 11 of the New Harmonized Value-Added Tax System Regulations provides an exemption where “the supply is made by a person that paid tax under section 220.05 or 220.07 … in respect of bringing the property into the participating province.” ...