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. … The Income Tax Act (ITA), Employment Insurance Act (EIA), and Canada Pension Plan (CPP) which govern the withholding, remittance, and collection of payroll/source deduction amounts, contain no statutory analogue to the ETA provisions which would allow for the postponement of collection of amounts owing which are under appeal or objection. … Where the taxpayer has made … arrangements [with CRA collections], CRA collections does have the administrative authority to withdraw any collection actions such as garnishment, so long as the payment arrangement remains in good standing. ...

You provide the right to use goods with the right to use real property and the following criteria are met:  the term of the right to use the real property is 7 days or less  there is no separate charge for the right to use the goods  the total amount your customer pays for the right to use the real property is the same as, or only marginally different from, the total amount your customer would have paid if they had not received the right to use the goods 2. You provide the right to use goods with a non-taxable service and the following criteria are met:  the main purpose of the contract with your customer is the non-taxable service and not the right to use the goods  there is no separate charge for the right to use the goods and they are included as part of the service  the total amount your customer pays for the service is the same as, or only marginally different from, the total amount your customer would have paid if they had not received the right to use the goods ...

CRA stated: One of the conditions for making a section 167 election is that if the supplier is a registrant, the recipient must be a registrant … [which] is a question of fact … There is no provision deeming a predecessor (in this case, Newco) to acquire the characteristics of its successor Amalco. ...

The circumstances of these supplies can be differentiated from the supply of [the Assessment] in that the purpose for these supplies is the examination by the physician or the review of a report by the physician. […] [The Assessment] supplied by [ACo], […] is a multi-disciplinary assessment conducted by a number of different service providers including…. ...

Therefore … subparagraph 173(1)(d)(i) would not apply …. ...

. … In this case, the CRA would treat 90% of the claim under Category 1 and the other 10% would likely fall under Category 2. ... CRA responded: VDP applicants are required to submit information for the 4 calendar years before the date the application is filed for applications processed under Category 1 or Category 2 … [and] would only be expected to include information and payment of the estimated tax owing for 4 calendar years before the date the application is filed even if the error was made for more than the 4 calendar years prior to the date of filing. … If an application that was believed to fall under Category 1 (GST/HST wash transaction) or Category 2 (General program) is reclassified, in part or in whole to Category 3 (Limited program) by the CRA, the applicant will be required … to pay the additional taxes …. ...

11 April 2016 CRA Press Release “Government of Canada cracks down on tax evasion”-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) expansion of audit review of aggressive tax avoidance and evasion/embedded lawyers [T]he Government of Canada will invest over $444 million to enhance the Canada Revenue Agency’s (CRA) ability to detect, audit, and prosecute tax evasion – both at home and abroad. …This will result in a twelve-fold increase in the number of tax schemes examined by the CRA…[and] will increase the number of examinations focused on high-risk taxpayers – from 600 per year to 3000 per year – and will bring in $432 million in new tax revenue. ...

. … For example, in the case of an annual bonus paid by an eligible employer to an eligible employee, it would generally be reasonable to consider that the annual bonus was earned throughout the fiscal period to which it relates. ... It would also be reasonable, for purposes of computing baseline remuneration, to calculate the average weekly eligible remuneration by dividing the bonus amount by the number of weeks included in the period to which it relates …. [Q.17-6] Apportionment of commissions To determine whether a commission payment is in respect of a specific week, it is necessary to review the complete set of facts pertaining to a particular situation, including the employment contract … [and] practices specific to a particular industry …. ...

Examples of acceptable variations – COLA Many RPPs provide cost-of-living adjustments that are based on the full Consumer Price Index (CPI). ... Commutation of PV of RPP benefits to acquire life annuity [T]he terms of the plan … might allow a member to use their commuted value to buy a life annuity from a licensed annuity provider. … A commuted value cannot be used to purchase an annuity that is materially different from the RPP, based on the plan as registered. ... Any excess must be distributed on a taxable basis If the commuted value is greater than the cost to buy an annuity that replicates the RPP benefits, the excess commuted value cannot be used to provide higher annuity payments under the annuity contract. … Under [Reg.] 8502(d)(ix) … the portion of the commuted value that is in excess of the annuity acquisition cost can be paid in cash to the individual and must be included in income for tax purposes. … Use of excess assets e.g., in IPP to purchase further benefits If there are excess assets in the RPP, to the extent that lifetime retirement benefits and ancillary benefits are not at the maximum allowable under the Act, benefits can be enhanced through a plan amendment before being settled by an annuity purchase. ...

These and related changes are reflected in the updated CRA Webpage on the “ Pertinent loans or indebtedness (PLOI) ”. ...