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Administrative Policy summary
May 2013 ICAA Roundtable, Q. 6 (reported in April 2014 Member Advisory) -- summary under Subsection 159(2)
. … The CRA is currently working on streamlining the process to expedite the processing of these requests by improving internal efficiencies…. ...
Administrative Policy summary
Gouin-Toussaint, September 1989 Revenue Canada Round Table (Dec. 89 Access Letter, ¶1040) -- summary under Subsection 256(5.1)
Gouin-Toussaint, September 1989 Revenue Canada Round Table (Dec. 89 Access Letter, ¶1040)-- summary under Subsection 256(5.1) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(5.1) A public corporation and a private corporation plan to each acquire ½ of the common shares of a third corporation ("Opco"). ...
Administrative Policy summary
31 October 2012 TPM-14 "2010 Update of the OECD Transfer Pricing Guidelines" -- summary under Subsection 247(2)
31 October 2012 TPM-14 "2010 Update of the OECD Transfer Pricing Guidelines"-- summary under Subsection 247(2) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2) After noting that in the 2010 version of the OECD Transfer Pricing Guidelines "there is no strict hierarchy to be applied to the selection of a transfer pricing method," CRA stated that: These changes do not firmly de-emphasize the natural hierarchy but they refocus the topic on what is truly relevant – the degree of comparability available under each of the methods and the availability and reliability of the data. ...
Administrative Policy summary
2 December 2014 CTF Roundtable, Q5 -- summary under Subsection 103(1)
. … The CRA would seek to apply subsection 103(1) (and may also apply the general anti-avoidance rules…) to the allocation of income under the amended partnership agreement. ...
Administrative Policy summary
Excise and GST/HST News - No. 89 (Summer 2013) under "Time limits for claiming a public service bodies' rebate (PSB rebate)" -- summary under Subsection 259(3)
. … If a PSB has already claimed a PSB rebate for a claim period and subsequently discovers additional GST/HST that was paid or payable during that claim period, the PSB must adjust the previously filed rebate application to claim a PSB rebate for the additional GST/HST. ...
Administrative Policy summary
2 December 2014 CTF Roundtable, Q. 7 -- summary under Article 29A
. … [S]ome of the more significant comparative ratios are summarized below: ...
Administrative Policy summary
Income Tax Technical News, No. 9, 10 February 1997 -- summary under Subparagraph 53(1)(e)(i)
. … In circumstances where there is a possibility of double taxation, we are prepared, in the context of a ruling request, to apply the law in a manner such that a taxpayer is not taxed twice on the same amount. ...
Administrative Policy summary
28 March 2013 Interpretation Case No. 141341 -- summary under Subsection 27(6)
Therefore, the amount of ITC to be recaptured would be limited to the large business participant's interest, or $2,666.64 ($8,000 [HST Provincial Component] X 33 1/3 %). ...
Administrative Policy summary
Guidance on the Canada-U.S. Enhanced Tax Information Exchange Agreement 20 July 2020 -- summary under Subsection 265(2)
. … 7.18 Self-certification forms have been developed by the CRA to assist financial institutions in establishing the status of account holders under Part XVIII and Part XIX.... ...
Administrative Policy summary
17 May 2012 Interpretation File 97556 -- summary under Financial Service
Since CanCo and [its parent] USCo are not Interac Association Members, the Processing Services are contracted to a third party, […], an Interac Member and Acquirer. ...