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News of Note post
8 August 2021- 10:58pm 4431472 Canada – Federal Court sets aside a CRA decision not to reassess on the basis that it was unclear whether it was a final decision Email this Content A Canadian corporation (“443 Inc”) filed its tax returns on the basis that distributions received by it from a trust were distributions of fee income (the “GAM fees”). ... In explaining the significance of the distinction between these two alternatives, Pamel J had earlier noted the statement in IT-335R2 regarding s. 56(2) that “it is normally the … CRA … practice not to assess the same income twice. ...
News of Note post
20 December 2021- 10:57pm Godcharles – Quebec Court of Appeal applies s. 68 to reallocate between a retirement home’s business operations sold by one vendor and the home sold by the other vendors Email this Content A group of unrelated individuals were the co-owners of a seniors’ residence, which was leased by them to the corporate operator of the residence (“9118”), whose shares they owned in the same proportions as the residence. ... Agence du revenu du Québec, 2021 QCCA 1843 under s. 68(a), s. 69(1)(b)(i), s. 251(1)(c) and General Concepts – FMV – real estate. ...
Current CRA website
T2 Corporation – Income Tax Guide – Chapter 8: Page 9 of the
Line 840 – Tax instalments paid On line 840, report all instalment payments you made for the tax year. ... Line 894 – Refund code If entitled to a refund, enter one of the following codes on line 894: enter " 1 " or leave this line blank if you want the CRA to send you the refund enter " 2 " if you want the CRA to transfer the refund to next year's instalment account enter " 3 " if you want the CRA to apply the refund to another liability (such as an expected debit from a reassessment) or to a different account. ... Line 957 – Tick the yes or no box. Lines 958 and 959 – If you answer no to line 957, provide the first and last names and telephone number of a contact person. ...
Article Summary
Hersh Joshi, Jack Silverson, "Understanding and Doing Business with Tax-Exempt Entities", 2018 Conference Report (Canadian Tax Foundation), 29:1 – 35 -- summary under Clause 149(1)(o.2)(iii)(B)
[fn 18: 2012-0461151E5]. … [T]rade payables not evidenced in writing are not similar to bonds, notes, debentures, or mortgages. … Bonds etc. issued by LP are not issued by (o.2) corp as limited partner (pp. 29:10- In some common-law jurisdictions, a debt obligation issued by a partnership might be considered to be a debt obligation issued by the partnership’s investors…. ... OMERS … denies the existence of any legal relationship between the limited partners and a third party that has entered into a contract with the limited partnership (or, as the court more precisely puts it, a contract between the third party and the general partner acting in its capacity as general partner of the limited partnership). … [S]ection 253.1 provides that, for the purposes of paragraph 149(1)(o.2) and other listed provisions, when a trust or a corporation holds an interest as a member of a partnership and, by operation of law, the liability of the partner as a member of the partnership is limited, the partner is not considered to be carrying on the business or other activity of the partnership solely by virtue of acquiring or holding an interest in the partnership. … The issuing of debt should be viewed as part of the “business” or “activity” of the partnership that would not, as a result of section 253.1, be considered to be carried on by the investment corporation. … Consolidated Mogul … [stated:] [T]he financing function of a mining company is an integral part of its business. … Accordingly … [t]he result of such application is that the issuance of a debt obligation by a limited partnership should not be attributed to its limited partners. Guarantee of LP debt does not engage s. 149(1)(o.2)(iii)(B) (pp. 29:13- 16) [O]n June 26, 2013…the phrase “that had not issued debt obligations” was replaced with “that had not... issued bonds, notes, debentures or similar obligations.”… [A]ccording to … Federated Co-operatives … “similar obligation” is a narrower category than “obligation.” ...
Current CRA website
Reporting fees for service external stakeholder working group – What we heard – Summary
Reporting fees for service external stakeholder working group – What we heard – Summary On this page: Background information Working group overview Takeaways Contact us Background information Reporting fees for service (RFS) is the legislated obligation requiring Canadian businesses and organizations to report fees paid for services in prescribed form to the Canada Revenue Agency (CRA). ... They: emphasized that the T4A slip is not the appropriate reporting vehicle for RFS since this slip is typically associated with payroll – this could create confusion and administrative challenges for businesses and organizations thought the current $500 reporting threshold may be too low because it would likely increase the administrative burden without offering added compliance benefits noted a lack of clarity on what constitutes a reportable service, particularly in cases when goods and services are not distinguished on an invoice called for enhanced communication and educational resources to ensure businesses and organizations fully understand their RFS reporting obligations recommended a phased implementation approach focusing on specific sectors first to help businesses and organizations become aware of and comply with the RFS requirement supported the creation of exemptions to alleviate administrative burden based on size and type of business These findings underscore the importance of creating a streamlined, flexible, and accessible reporting process that accommodates the diverse needs of businesses and organizations while advancing the CRA’s goals of addressing the underground economy and promoting tax fairness. ... Contact us For more details on the findings from the working group, you can request a copy of the Reporting fees for service external stakeholder working group – What we heard report by sending an email to ReportingFeesService-DeclarationHonorairesService@cra-arc.gc.ca. ...
Archived CRA website
ARCHIVED – Education Tax Measures – Study Abroad
ARCHIVED – Education Tax Measures – Study Abroad Archived content Information identified as archived is provided for reference, research or recordkeeping purposes. ... For more details please see our publication RC192, Information for Students – Educational Institutions Outside Canada. 5. ...
22 March 2016- 2:09am UBS AG – UK Supreme Court infers a Parliamentary intention to give relief for restrictive conditions affecting shares' marketability only where those conditions have a commercial purpose Email this Content Lord Reed found that a scheme to avoid income tax on bankers’ bonuses, which entailed awarding the employees redeemable shares in an offshore company which were subject to a commercially remote risk of forfeiture of all or a significant portion of their value (e.g., in the case of one bank, forfeiture of the shares if the employee was dismissed for misconduct or voluntarily resigned within the next six weeks), did not avoid immediate taxation on the value of the offshore company shares when awarded to them. ... Commissioners for HMRC, [2016] UKSC 13 under General Concepts – Tax Avoidance, and General Concepts – Fair Market Value – Shares. ...
Archived CRA website
ARCHIVED – T4A Slip – Box 048
ARCHIVED – T4A Slip – Box 048 Archived content Information identified as archived is provided for reference, research or recordkeeping purposes. ... Previously, payments for fees for services were reported in Box 28 – Other income, along with many other types of income. ...
News of Note post
26 January 2021- 11:11pm CIBC – Federal Court of Appeal finds that VISA provided a GST/HST-exempt financial service to CIBC Email this Content CIBC issued Visa credit cards and utilized the Visa payment system, for which it paid fees to VISA. ... To describe the benefit that CIBC obtained from Visa’s services … as "quintessentially administrative," [as was done by the Tax Court] does not … adequately recognize the reality of the benefit that CIBC derived. ... Canada, 2021 FCA 10 under Financial Services (GST/ HST) Regulations – s. 4(2)(b). ...
GST/HST Interpretation
10 June 2022 GST/HST Interpretation 236273 - – [Adjustments to previous returns -] […] foreign currency conversion
10 June 2022 GST/HST Interpretation 236273- – [Adjustments to previous returns-] […] foreign currency conversion Unedited CRA Tags ETA Part IX, 159 Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. GST/HST Rulings Directorate Place de Ville, Tower A, 11th floor 320 Queen Street Ottawa ON K1A 0L5 [Addressee] Case Number: 236273 Dear [Client]: Subject: GST/HST INTERPRETATION [Adjustments to previous returns-] […] foreign currency conversion Thank you for your email received on [mm/dd/yyyy], where you requested our opinion concerning various requests made by […][a registrant]. ... [INTERPRETATION GIVEN] With respect to retroactively adjusting the method for converting the value of consideration, […], [a registrant] may request an adjustment to its previously filed net tax returns within four years after the later of the day the return was filed and the due date of the return. ...