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Is it just the taxpayer – is the taxpayer the unit of risk, so that taxpayers are either risky or not risky? ... Canadian law gives the Minister broad power to compel the production of information – the word “any” is there in the Act – but of course judges have imposed a reasonableness test. ... We are working around in the T1 space – letting taxpayers “load in” their T4. ...

This is claimed by filing form T3A — Request for Loss Carryback by a Trust. ... Official Response 26 November 2020 STEP Roundtable Q. 13, 2020-0847201C6- GRE & section 216 election Q.14 Adjusted Aggregate Investment Income Subsection 125(5.2) is an anti-avoidance rule which may apply if a particular corporation transfers “property” at any time, either directly or indirectly to another corporation which is related to but not associated with the particular corporation, in circumstances where one of the reasons the loan or transfer was made was to reduce the “adjusted aggregate investment income” (“AAII”) of the particular corporation. ... Because of these strict requirements, practitioners have for years been concerned — and experienced the results of such concerns — that many estates may not be eligible for such planning because of the tight timelines and requirements for an actual disposition. ...

Of course, the screening process technically begins even earlier, with the audit team’s decision on whether to refer the matter to Headquarters in the first place, so that it is possible that some things get missed – which is to say that, from a taxpayer perspective, things could certainly be worse! ... We had a new communique out to our auditors, which should be on our website fairly soon, that talks about what we call audit agreements – that’s a settlement at audit stage – what’s involved and when we engage that process. ... Written communication is not an effective way to address certain emergent Questions – such as whether particular words or statements under consideration are being taken out of context. ...

Brault: The CRA is currently part of three ICAP 2.0 risk assessments – one is complete and two are still in progress. ... Brault: The document is in final stages of approval – it should hopefully be ready in weeks rather than months. ... There is quite a number of applications – over 2 million if you look period-by-period – so that 100% coverage is infeasible. ...

Codifying those principles can be tricky – I understand why the drafters went with “appropriate in the circumstances.” ... The Communiqué puts some conditions around it – reasonableness and restraint. ... Not every file will be resolved this way – one of our criteria is that the adjustment in question must be at least $100 million. ...

In the situation described above, will CRA consider that UKco has a permanent establishment in Canada under Article 5 of the Canada – U.K. ... ASIC Miners ASIC miners, on the other hand, are designed and optimised to perform a single task – mine crypto-assets. ... (iii) Part II Section 3A – Surplus Accounts – 4. Upstream Loan Rules (Table) Column 2 of the Table requires reporting entities to identify if a specified debtor (as defined in subsection 90(15)) owes an amount to the foreign affiliate (or a partnership of which the foreign affiliate was a member) at any time during the reporting period. ...

At the 2015 STEP – CRA Roundtable, CRA stated that an individual can only have one estate. ... Anyone wanting to access that Q & A, can go to the CRA website and use the search tool to enter in “graduated rate estate”- and the Q & A will be the first hit for the search. ... Further, the settlor / grantor can exercise his / her power to revoke the trust at any time. ...

D4- Provincial allocation disputes At one time, the CRA employed a formal process — the Tax Re-Allocation Committee (TRAC) — for resolving provincial allocation disputes. ... E3- "Normal open-market" purchase in s. 39(3) 2014-0550401C6 E – 2014 TEI Liaison Meeting, Q. ... E6- S. 115.2(2)(b)(i)(B)- Forco share issuance to affiliated Canco 2014-0550421C5 E – 2014 TEI-CRA Liaison Meeting – Question E6 – Non-Resident Carrying on Business in Canada Where a non-resident engages a Canadian investment manager, the activities of the investment manager may cause the non-resident to be carrying on business in Canada for Canadian tax purposes. ...

.), 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. ...

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. ...