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Mandatory disclosure rules – Guidance, 15 August 2024 CRA Webpage-- summary under Subsection 237.4(6) Summary Under Tax Topics- Income Tax Act- Section 237.4- Subsection 237.4(6) Notifiable Transactions Due diligence- notifiable transactions – no reporting “A person who obtained the tax benefit would generally meet their due diligence obligations by asking their advisors about potential reporting obligations that might arise from the transactions (and being informed by their advisors that no such reporting obligations will arise on account of the transaction being a notifiable transaction or substantially similar to a notifiable transaction).” ...

GST/HST Memorandum 3-3-3, Place of Supply in a Province – Tangible Personal Property, August 2024-- summary under Section 1 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule IX- Part II- Section 1 Where Manitoba supplier personally delivers good to consignee in Ontario, who sells the goods to Quebec purchaser and has it couriered there, there are 2 supplies: in Ontario, and Quebec Example 9 – Delivery of goods sold on purchase/resale consignment basis A consignment sale under a purchase and resale arrangement is treated as two separate supplies that occur at the time the consignee sells the good to the final purchaser. ... Supply 1 – Sale by the Manitoba company to the consignee The sale of the good from the Manitoba company to the consignee is made in Ontario and is subject to the HST at a rate of 13% because the Manitoba company delivered the good to the consignee in Ontario. Supply 2 – Sale by the consignee to the final purchaser The second supply is the sale of the good from the consignee to the final purchaser. ...

GST/HST Memorandum 3-3-4, Place of Supply in a Province – Real Property, August 2024-- summary under Subsection 136.1(1) Summary Under Tax Topics- Excise Tax Act- Section 136.1- Subsection 136.1(1) Supply of building for each lease interval is where the building is situate Example 4 – Lease of real property in a particular province Pursuant to a lease agreement, a company in New Brunswick leases a commercial office building situated in New Brunswick to a company in Ontario for a period of 10 years. ...

GST/HST Memorandum 3-3-3, Place of Supply in a Province – Tangible Personal Property, August 2024-- summary under Section 3 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule IX- Part II- Section 3 Where Manitoba purchaser itself retains the common carrier and PEI vendor merely contacts the carrier when ready, the place of supply is that of legal delivery in PEI Example 3 – Delivery of a good by a common carrier retained by the purchaser A manufacturer in Prince Edward Island sells a good to a wholesaler in Manitoba. ...

Excise and GST/HST News – No. 119, April 2025-- summary under Section 9 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part II- Section 9 list of the particulars that should be recorded by a supplier of contact lenses or eyeglasses (if it does not have the prescription) The Supply of Prescription Eyeglasses and Contact Lenses … Alternative of retaining particulars of prescription (pp. 1-2) In Excise and GST/HST News No. 113 CRA indicated that the simplest way for a supplier to demonstrate that a supply of contact lenses or eyeglasses was made to a consumer pursuant to a valid prescription or assessment record, as required by s. ...

GST/HST Memorandum 3-3-4, Place of Supply in a Province – Real Property, August 2024-- summary under Section 136.2 Summary Under Tax Topics- Excise Tax Act- Section 136.2 Proration of single option to buy two properties based on the properties’ relative values Example 3 – Option to purchase real property in different provinces A builder in Ontario is advertising a new home for sale in Ontario for $1,000,000. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.6-- summary under Subsection 284.1(2) Summary Under Tax Topics- Excise Tax Act- Section 284.1- Subsection 284.1(2) late filing a financial institution return is not particularly relevant to the imposition of an ETA s. 284.1 penalty When asked about the application of the ETA s. 284.1 penalty to an unfiled return, and whether a zero dollar line item triggers the minimum penalty amount of $1,000, CRA stated: Where an information return that was not filed on time is subsequently filed, and the correct amount reported on the particular line is zero … there would be no penalty under subsection 284.1(1) based on the formula for calculation the penalty in that subsection. … Where an information return that was not filed on time is subsequently filed, and the correct amount reported on the particular line is zero … a penalty under subsection 284.1(2) would be calculated based on the formula in that subsection. ...

Alexandra MacLean, "CRA Audits of Large Corporations- The view from ILBD" under Responses to recent adverse decisions – Univar, 27 November 27 2018 CTF Annual Conference presentation.-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) Univar GAAR doctrine entails looking at reasonable alternative transactions Univar found that the result of the cross-border surplus-stripping transactions before it could have been equally accomplished if the non-resident indirect purchaser of Canco had instead been able to access the surplus of Canco by using a subsidiary Buyco with high paid-up capital. CRA indicated that Univar signifies that, in the context of a consideration of the general anti-avoidance rule, there can be an examination of what the taxpayer could have done versus what the taxpayer did do – but CRA is examining what limitations should be placed on this approach. For example, the mooted alternative must have been commercially reasonable – something that the taxpayer could actually have done. ...

26 February 2019 Toronto CRA & Tax Professionals Seminar-- summary under Subsection 247(2) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2) BEPS has not substantially affected CRA's transfer-pricing practices CRA comments relating to the mooted BEPS impact on CRA transfer-pricing practices included: BEPS Actions 8 to 10 did not effect substantial changes, i.e., the underlying principles are the same. ... Canada has not adopted the simplification measure concerning low-value-added intragroup services – so that, rather than accepting a flat markup on intragroup service-charges because of the OECD guidance, CRA will continue to rely on IC87-2R to govern intragroup pricing until adoption of a new measure. ... The Canadian penalty regime is not more rigorous than Action 13 – instead it is that CRA's audit process is more rigorous than in most jurisdictions. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.8-- summary under Section 133 Summary Under Tax Topics- Excise Tax Act- Section 133 s. 133 determines time of acquisition for ITC purposes In finding that input tax credits can generally be claimed by a builder for invoices issued subsequent to the date of self assessment on substantial completion and first occupancy of a multiple unit residential complex (a “MURC”) for work done by suppliers for goods and services sold/installed performed prior to the first tenant move-in, CRA stated: Under section 133, a supply of property or a service is generally considered to be made at the time that the agreement to provide the property or service is entered into. ... The time at which the consideration for a supply of property or a service becomes due under section 152 … does not impact the time at which the supply is considered to be made, nor does that time impact the purpose for which the recipient of the supply acquired the property or service. … ...