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GST/HST Audit and Examination Manual, 9 – Taxpayer Rights and Taxpayer Relief – 9.1.6.3 “ The right to privacy and confidentiality-- summary under Subsection 295(5) Summary Under Tax Topics- Excise Tax Act- Section 295- Subsection 295(5) Informal request in lieu of ATIP request When an access to information and privacy (ATIP) request is received, the Access to Information and Privacy Directorate of the Public Affairs Branch forwards the request to the appropriate party(ies) to obtain the relevant information. ... Permitted scope of informal request Some examples of information that can be released to a registrant or authorized representative under an informal request include: • the T20 Report • external and internal correspondence, including memoranda, appropriately severed where necessary • related correspondence with Headquarters such as technical interpretation requests or opinions and referrals to specialized sections about a specific person • working papers, excluding third-party information, leads, disclosure of audit techniques, and information from informants • related reports from external and internal valuators, appraisers and electronic commerce audit specialists, • severed versions of operations manuals available to the public Examine the documents before releasing them to ensure no confidential information about a third party is released. Prohibited disclosures Examples of information that cannot be released are: • information obtained in confidence during an audit or examination that may prejudice the results of the audit or examination, such as Criminal Investigation reports, Royal Canadian Mounted Police reports, or documents obtained as part of an investigation • audit techniques and specific audit guidelines • information about investigations in process when a decision is pending • documents of a related file under investigation • confidential information about another registrant • Department of Justice correspondence and information under solicitor-client privilege, including legal opinions from the Legal Services Branch (for more information, go to Disclosing legal opinions and Use of legal opinions inside the Agency) • specific advice and recommendations developed by or for a government institution or minister of the Crown that may restrict the CRA's ability to administer the ETA if they are disclosed • accounts of consultations and deliberations involving officials or employees of a government institution or a minister of the Crown that may reasonably be expected to cause injury or restrict the CRA's ability to administer the ETA if disclosed • information released to a third party, other than specifically permitted by paragraph 295(5)(d) of the ETA or where consent is given by the registrant • copyright material • computer printouts from CRA computer systems. ...

SR & ED 95-02R "Science Eligibility Guidelines for the Oil & Gas of Mining Industries"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...

14 May 2019 IFA Conference – Stephanie Smith on MLI – MLI Progress-- summary under Article 19 Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 19 majority of arbitration Articles provide for baseball-style arbitration Approximately 20 of Canada’s treaties will be updated to include arbitration. ...

14 May 2019 IFA Conference – Stephanie Smith on MLI – MLI Progress-- summary under Article 4 Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 4 post MLI, most of Canada’s treaties will have a residence tie-breaker rule When the Notice of Ways and Means motion for the implementation of MLI was tabled, Canada indicated that it would adopt additional provisions of the MLI including the tie-breaker rule for dual-resident entities. ...

15 May 2019 IFA Finance Roundtable – “Tracking Interest Rules & Umbrella Corporations”-- summary under Subsection 95(8) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(8) Finance has issued a comfort letter respecting umbrella corporation interests where there is no tax avoidance purpose It is not clear to Finance that the compliance burden on a Canadian investor under the tracking interest rules is unusually onerous compared with other compliance obligations under this part of the Act. ...

Application Policy SR & ED 96-01 "Reclassification of SR & ED Expenditures per Subsection 127(11.4)".-- summary under Subsection 127(11.4) Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(11.4) ...

14 May 2019 IFA Conference – Stephanie Smith on MLI – GAAR and PPT-- summary under Article 7(1) Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 7- Article 7(1) PPT applied 1st like any other Treaty benefit limitation rule, any remaining benefit subject to GAAR scrutiny Question: How to the GAAR and PPT interact? ... S. 4.1 of the ITCIA provides that “notwithstanding the provisions of a Convention … the GAAR, applies to any benefit provided under the Convention.” ...

3 November 1995 Interpretation 950229 – Sale of Rebuilt Cottage – ITCs on Costs Incurred for Rebuilding the Cottage-- summary under Section 192 Summary Under Tax Topics- Excise Tax Act- Section 192 rebuilding of fire-damaged cottage The subject cottage, that was rented out as a principal place of residence (ie., a residential complex) was subject to a fire in early 1995 that almost destroyed it. ...

IT-363R2 (Cancelled) – Deferred Profit Sharing Plans – Deductibility of Employer Contributions and Taxation of Amounts Received by a Beneficiary 28 May 1993-- summary under Subsection 147(10.1) Summary Under Tax Topics- Income Tax Act- Section 147- Subsection 147(10.1) 14. ...

SR & ED 95-01R "Linked Activities- Regulation 2900(1)(d)"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...