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December 2017 GST/HST Memorandum 16.5 – Voluntary Disclosures Program-- summary under Subsection 281.1(2) Summary Under Tax Topics- Excise Tax Act- Section 281.1- Subsection 281.1(2) Effective 2018 This memorandum applies to Voluntary Disclosures Program applications received on or after March 1, 2018…. ... Track 1 – GST/HST wash transactions 12. Category 1 specifically provides relief for applications involving GST/HST wash transactions that are eligible for a reduction of penalty and interest under the policy set out in GST/HST Memorandum 16-3-1, Reduction of Penalty and Interest in Wash Transaction Situations. … Track 2 – General program 13. ... Track 3 – Limited program 15. In general terms, Category 3 provides limited relief for applications that disclose non-compliance where there is an element of intentional conduct on the part of the registrant or a closely related party including, but not limited to, situations where: GST/HST was charged or collected but not remitted; efforts were made to avoid detection (for example, participation in underground economy); the disclosure is made after an official CRA statement regarding its intended specific focus of compliance (for example, the launch of a compliance project or campaign) or following broad-based CRA correspondence (for example, a letter issued to registrants involved in a particular sector about a compliance issue); there had been deliberate or wilful default or carelessness amounting to gross negligence. 16. ...

Round Table, Q.15-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt There is no repayment for the purposes of s. 20(1)(hh) when shares are converted to a debt security and the parties are in essentially the same situation before and after the conversion. ...

IC86-4R3 "Scientific Research and Experimental Development"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...

IT-151R4 "Scientific Research and Experimental Development Expenditures"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...

IT-151R4 "Scientific Research and Experimental Development Expenditures"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...

.-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...

Eligibility of Work for SR&ED Investment Tax Credits Policy, 24 April 2015-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Regarding the second step of CRA's two-step analysis of SR&ED ("determine if there is SR&ED" and "determine the extent of eligible work"), CRA states: Support work must be the following: It must be commensurate with the needs of the basic research, applied research, or experimental development work undertaken in Canada. ...

18 September 2013 Draft examples to illustrate key concepts in the Eligibility of Work for SR&ED Investment Tax Credits Policy-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development CRA provides 10 examples to clarify its position on its SR&ED Investment Tax Credits Policy: Examples dealing with subheading 2.1.1 ("Was there a scientific or a technological uncertainty—an uncertainty that could not be removed by standard practice? ...

Eligibility of Work for SR&ED Investment Tax Credits Policy, 24 April 2015-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development In the first step of CRA's two-step analysis of SR&ED ("determine if there is SR&ED" and "determine the extent of eligible work"), CRA sets out five questions, based on the s. 248(1) definition of SR&ED: Subheading 2.1.1: Was there a scientific or a technological uncertainty—an uncertainty that could not be removed by standard practice? ...

Mandatory disclosure rules – Guidance, 15 August 2024 CRA Webpage-- summary under Subsection 237.4(7) Summary Under Tax Topics- Income Tax Act- Section 237.4- Subsection 237.4(7) Notifiable Transactions Reasonable expectation to know – no reporting Only advisors who know or are reasonably expected to know of their reporting requirements are required to file – for example, this generally would not extend to “more junior employees and those who have limited roles that do not give them visibility of the broader transaction or series as well as the associated tax treatment and tax benefit” even if their employer did not file. ...