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Concerns expressed by the Joint Committee regarding s. 231.9 include: Where the taxpayer refuses to provide information on the basis of solicitor-client privilege and the Minister nonetheless issues a NNC, this could pressure the taxpayer into waiving privilege rather than undertaking the onerous NNC dispute process – suggesting that since a compelled waiver is not valid, the production of documents resulting from the NNC’s issuance would likely constitute an unreasonable search or seizure contrary to s. 8 of the Charter. ... This requirement for a review of correctness clashes with s. 231.9(9), which contemplates the Federal Court reviewing whether any CRA decision to reject a privilege claim in relation to a document covered by a NNC was reasonable, a review which generally would be limited to considering that decision in light of the material before the CRA decision maker – which, crucially, would not include the document for which privilege was claimed. In contrast, the Federal Court’s review under s. 231.7 of any compliance order sought by the Minister of a document for which the taxpayer claimed privilege would be applied under a correctness standard (likely including a review of the document) – so that there could be a situation (representing an affront to the rule of law) in which taxpayer was penalized under s. 231.9 for what was subsequently established not to be a failure. ...

18 May 2017- 11:51pm CRA confirms that the use of space-confirmed, but not standby, passes by airline employees is a taxable benefit Email this Content CRA confirmed that the use of space-confirmed airline passes by current airline employees, but not standby passes, is a taxable benefit which is valued at what it would have cost to purchase the space – whereas neither category of pass is taxable to retired employees. ...

Summary of 13 April 2017 Interpretation 162819 under ETA, s. 123(1) – office. ...

Summary of 29 May 2018 STEP Roundtable Q.16 under s. 248(1) – disposition. ...

Summary of 29 July 2019 Comfort Letter TL-23 entitled “Functional currency tax reporting- currency of Japan” under s. 261(1) – qualifying currency. ...

Summary of 12 November 2019 External T.I. 2019-0822161E5 F under Reg. 230(1) – “sale.” ...

Summary of 23 December 2022 Internal T.I. 2021-0880421I7 F under s. 125.7(1) – qualifying rent expense- (b)(i). ...

Summary of 20 June 2023 STEP Roundtable, Q.6 under s. 94(1) – resident beneficiary. ...

25 June 2024- 11:17pm CRA confirms no change to its administrative practice of not charging interest or penalties for insufficient instalment payments by trusts Email this Content CRA indicated that its release of two new forms- the T3 INNS3, Trust Instalment Voucher and the T3AO, Trust Amount Owing Remittance Voucher – does not signify any change to its current administrative practice of not charging interest or penalties for insufficient instalment payments by trusts. ...

Summary of 26 June 2024 External T.I. 2023-0961541E5 under s. 248(1) – retiring allowance. ...