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. … Whenever there is insufficient space on the Notice of Objection form to provide facts and reasons for the objection or the assessment information, you can always attach a separate sheet(s). … ...

8 March 2018 CBA Commodity Tax Roundtable, Q.9-- summary under Paragraph 142(2)(a) Summary Under Tax Topics- Excise Tax Act- Section 142- Subsection 142(2)- Paragraph 142(2)(a) Incoterms did not govern the place of delivery of goods Company B, a registered resident, agreed to sell tangible personal property (the “Property”) to Company C, an unregistered non-resident, using the Incoterms® 2010 DAP Port of Liverpool, U.K. so that delivery and title transfer was to occur at the U.K. destination – although the parties agreed that Company C was to indemnify Company B if the Property were lost or damaged in transit. ... Our response … would not change if it were established that Company C’s affiliate (and not Company C itself) provided the commercial indemnity in a side agreement. ...

CRA responded: The assessment will be based on the … legislation, which states that tax preparers who prepare more than 10 returns must file them electronically. ... These restrictions will be considered during assessment. … Similarly, please consider the due diligence issue where a tax professional has been engaged to prepare a return for a person for whom no one is authorized to sign a T183. ...

Cameco Corporation (2019 FCA 67), CRA Webpage-- summary under Paragraph 231.1(1)(a) Summary Under Tax Topics- Income Tax Act- Section 231.1- Subsection 231.1(1)- Paragraph 231.1(1)(a) CRA can infer and assume where, post-Cameco, taxpayers refuse interviews After noting that it will not seek to appeal Cameco, CRA indicated that this case decided: [T]he Minister … does not have the authority to compel the employees requested by the CRA to attend interviews and answer oral questions under a general audit and inspection rule of the Income Tax Act. …[T]he FCA … also stated that: all taxpayers should fully cooperate with reasonable requests arising in the course of an audit; it remains open to the Minister to make inferences when no answer is given; and the Minister is free to make assumptions and to assess on that basis. ...

. … On the other hand, for [sponsorship packages A, B, and C], although the sponsors receive the use of real property, they also receive a multitude of promotional services as part of the sponsorship package. ... Therefore, the entire package would be deemed not to be a supply because of section 135 …. ...

CRA responded As indicated in … 37442 (July 30, 2002) a decision on whether to accept a backdated effective date for a section 211 election falls within the purview of the Domestic Compliance Programs Branch … [which] will only consider the backdating of a section 211 election in exceptional circumstances. ...

. … Furthermore, if the operator meets the definition of “builder,” then the operator is within the deeming rules under subsection 191(3) and will be required to report and remit the GST/HST that is deemed under subsection 191(3) to have been collected by the builder. … Even if the operator is a “builder” that is required under subsection 191(3) to report and remit the tax on the self-supply of the MURC, it may not necessarily be entitled to a rebate under subsection 256.2(3) if the residential unit does not meet the definition of a “qualifying residential unit” or if any of the other conditions under section 256.2 for claiming the rebate are not met. ...

. … 12. Transactions between entities that are branches/divisions of the same provincial/territorial government registrant are not treated as supplies for purposes of the GST/HST. … 13. ...

Frequently asked questions- Canada emergency wage subsidy (CEWS) CRA Webpage 24 September 2021-- summary under Subparagraph (c)(ii) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Qualifying Entity- Paragraph (c)- Subparagraph (c)(ii) No required link of revenue decline to COVID / Example of application of alternative approach 5. ... [T]he employer is under no obligation to prove that the decline in revenue is related to the COVID-19 crisis. … Example 5D An eligible employer is determining if it has experienced the required reduction in revenue to qualify in order to claim the wage subsidy for the first claim period, from March 15 to April 11, 2020. ...

27 February 2020 CBA Roundtable, Q.2-- summary under Subsection 301(4) Summary Under Tax Topics- Excise Tax Act- Section 301- Subsection 301(4) s. 301(4) request granted only in exceptional circumstances Regarding its policy regarding requests under s. 301(4) for the Minister to waive reconsideration of an objection, CRA stated: On receipt of [such] a request … the case will be assigned and reviewed at the earliest opportunity. ... Headquarters Appeals may be consulted on the waiver request depending on the impact or sensitivity of the case. … If the request is not granted, the objector will receive a letter advising them of the decision and the case will proceed to be reviewed with the other GST/HST objection workload. ...