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CRA responded that “only the expenses that are reasonable to consider to be attributable to the activities generating the [SCI] income … should be considered” as deductions from the SCI income. ...

15 April 2018- 11:47pm CRA considers that a dietary supplement is not zero-rated Email this Content Subject to a long list of exclusions, the ETA zero-rates “supplies of food or beverages for human consumption (including … ingredients to be mixed with or used in the preparation of such food or beverages).” ...

The Queen, 2018 CCI 73 under s. 15(1) and General Concepts – Effective Date. ...

Summary of 29 May 2018 STEP Roundtable, Q.6 under s. 120.4(1) – excluded shares. ...

Summary of 29 May 2018 STEP Roundtable, Q.7 under s. 120.4(1) – excluded shares. ...

13 September 2018- 12:28am CRA indicates that a partner assignment of its specified partnership business limit may be amended within the statute-barring period Email this Content CRA confirmed that its position- that an associated group of Canadian-controlled private corporations can file amended T2 Schedule 23s providing an amended business limit allocation agreement provided that this does not change the amount allocated to any associated corporation for a taxation year for which a reassessment is statute-barred – also essentially applies to an amended assignment of a partner’s specified partnership business limit. ...

25 September 2018- 12:42am CRA notes that wire transfers can get lost because of intermediary banks cutting off essential characters Email this Content CRA observed that “intermediary banks often have a limit on the number of characters allowed in [a wire transfer] transaction, so this can result in some essential information being cut off” thereby resulting in difficulties allocating payments from non-residents and others to the correct account – and stated that “Currently, the best way to ensure that a wire transfer is successful is to also send a fax with the account information.” ...

28 October 2018- 9:48pm Finance addresses policy re sourcing of student moving expenses Email this Content A Finance official was content with the current tax policy of allowing students to deduct eligible moving expenses from scholarship and research grant income (and from employment income if “a full-time student … also moves to take up an employment”) but not from educational assistance payments received out of a registered education savings plan, noting inter alia that “an individual’s scholarships and research grants are more closely tied to a relocation site than income from [an RESP].” ...

28 December 2018- 12:39am CRA confirms that it usually does not assess the recipient for GST/HST Email this Content In response to a suggestion that CRA is starting to use s. 296(1)(b) to assess the recipient of taxable supplies (rather than the supplier) outside of an insolvency context, CRA confirmed that it “generally” will not assess the recipient, but may do so “in circumstances of potential revenue loss,” and that its “usual practice … is to look to the supplier.” ...

27 January 2019- 11:14pm CRA confirmed that a taxpayer can appeal to a CRA employee’s supervisor and that Appeals should refer new information first requested by Audit back to Audit Email this Content CRA confirmed that a taxpayer has the right, if it disagrees with how its concerns were addressed by an employee, “to discuss the matter with the employee’s supervisor” – and also confirmed that: A protocol was initiated at the end of 2015 between the Audit and Appeals branches. ...