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Current CRA website
Line 25500 – Prescribed Zones – British Columbia
Line 25500 – Prescribed Zones – British Columbia Place names followed by numbers are Indian reserves. ... British Columbia Table of the prescribed northern or intermediate zones for British Columbia Zone A – Prescribed Northern Zones Zone B – Prescribed Intermediate Zones Andy Bailey Recreation Area Atlin Atlin Park Atlin Recreation Area Atlin-Teslin Indian Cemetery 4 Bear Camp Ben-My-Chree Bennett Blue River 1 Boulder City Boya Lake Park Callison Ranch Cariboo Meadows Cassiar (Troutline Creek) Centreville Classy Creek 8 Coal River Days Ranch Dease Lake Dease Lake 9 Dease River 2 Dease River 3 Defot Eddontenajon Ekwan Elleh Engineer Fireside Five Mile Point 3 Fontas Fontas 1 Fort Nelson Fort Nelson 2 Fraser (White Pass) Gleam Glenora Good Hope Lake Gutah Hiusta's Meadow 2 Horse Ranch Pass 4 Hyland Post Hyland Ranch Hyland River Park Iskut Jacksons Jennings River 8 Kahntah Kahntah 3 Kledo Creek Park Klua Kluachon Lake 1 Laketon Liard River Liard River 3 Liard River Hotsprings Park Lindeman Log Cabin Lower Post Magnum Mine Maxhamish Lake Park McDame McDames Creek 2 McDonald Lake 1 Meadows Mosquito Creek 5 Mosquito Flats Mount Edziza Park Mount Edziza Recreation Area Muddy River 1 Muncho Lake Muncho Lake Park Muskwa Nelson Forks New Polaris Mine Niteal Old Fort Nelson One Mile Point 1 Pavey Pennington Pleasant Camp Porter Landing Prophet River Prophet River 4 Prophet River Recreation Area Rainy Hollow Rupert Salmon Creek 3 Saloon Scotia Bay Sheslay Sikanni (railway siding) Silver Salmon Lake 5 Skooks Landing Smith River Smith River Military Reserve Snake 5 Snake River Steamboat Stikine River 7 Stikine River Recreation Area Stone Mountain Park Summit Lake Mile 392 Surprise Tahltan Tahltan 1 Tahltan 10 Tahltan Forks 5 Taku Taku 6 Taku River Tamarack Tarahne Park Tatcho Creek 11 Telegraph Creek Telegraph Creek 6 Telegraph Creek 6A Teslin Lake 7 Teslin Lake 9 Tetsa River Park Toad River Trutch Tulsequah Upper Tahltan 4 Weissener Lake 3 White Pass All places in the Queen Charlotte Islands/Haida Gwaiiare in a prescribed intermediate zone. ... John Fort Ware 1 Fowler Georgie 17 Germansen Landing Goodlow Grand Haven Groundbirch Gundy Haida Gwaii Halfway Lodge Halfway Ranch Halfway River 168 Hasler Flat Hickethier Ranch Hudson's Hope Hulcross Ingenika Ingenika Mine Iracard Kelly Lake Kilkerran Kisgegas Kiskatinaw Klewaduska 6 (Cataract) Kotsine 2 (Skutsil) Kshwan 27 Kshwan 27A Kuldo Kuldoe 1 Lexau Ranch Lone Prairie Lynx Creek Mackenzie, District Municipality of Manson Creek Mason Creek McKearney Ranch McLean Ranch Mesilinka River Meziadin Lake Mile 62 1 / 2 Moberly Lake Moberly Lake 168A Moberly Lake 169 Monias Montney Murdale North Pine North Tacla Lake 10 (Bates Creek) North Tacla Lake 11A (North End Meadow) North Tacla Lake 12 Old Hogem Parkland Peejay Pine Valley Pineview Pink Mountain Police Meadow 2 Pouce Coupe Premier Prespatou Progress Queen Charlotte Islands Reine-Charlotte, (îles de la) Rolla Rose Prairie Scamakounst 19 Seven Mile Corner Shearer Dale Sikanni Chief Simpson Ranch South Dawson South Parcel of Beaton River 204 Stewart Stikine Strandberg Creek Sucker Lake 2 Sundance Sunrise Valley Sunset Prairie Sweetwater Taylor Teko Tomslake Tremblay Tsaytut Island 1C Tsupmeet 5 (Patcha Creek) Tumbler Ridge Tupper Twidwell Bend Two Rivers Upper Cutbank Upper Halfway Urquhart Valley View Wabi Wagner Ranch Ware West Moberly Lake 168A Willow Valley Willowbrook Wonowon (Mile 101) Worth Page details Date modified: 2024-01-23 ...
Current CRA website
Offshore Compliance Advisory Committee – Minutes – November 17, 2017
Offshore Compliance Advisory Committee – Minutes – November 17, 2017 Friday, November 17, 2017 List of Participants OCAC Members Chairperson Colin Campbell Vice-Chair Kimberley Brooks Committee Members Catherine Brown Larry Chapman Regrets Committee Member Daniel Thornton CRA Attendees Commissioner Bob Hamilton Assistant Commissioner, International, Large Business and Investigations Branch Ted Gallivan Deputy Assistant Commissioner, International, Large Business and Investigations Branch Lisa Anawati Director General, Agency Change and Innovation Directorate Mireille Éthier Director, Accelerated Business Solutions Lab André Patry Manager, Strategic Research and Tax Gap Michelle Gouchie Principal Policy Analyst Stephanie Gan Acting Director General, International and Large Business Directorate Alexandra MacLean Acting Director, Abusive Tax Avoidance and Technical Support Division Len Lubbers Manager, Related Party Initiative Maggie Moscovoy Senior Technical Specialist Dawn Dannehl Director General, Offshore and Aggressive Tax Planning Directorate Gina Jelmini Senior Technical Advisor, International and Large Business Directorate Maureen O'Leary 1. ...
Current CRA website
Offshore Compliance Advisory Committee – Minutes – June 15, 2016
Offshore Compliance Advisory Committee – Minutes – June 15, 2016 Wednesday, June 15, 2016 Inaugural Meeting List of Participants OCAC Members Chairperson Colin Campbell Vice-Chair Kimberley Brooks Committee Members Marie-Pierre Allard Catherine Brown Larry Chapman Allan Lanthier Daniel Thornton CRA Attendees Minister of National Revenue The Honourable Diane Lebouthillier Assistant Commissioner, International, Large Business and Investigations Branch Ted Gallivan Deputy Assistant Commissioner, International, Large Business and Investigations Branch Lisa Anawati Director, Horizontal Programs Division Joanne Heidgerken Manager, Voluntary Disclosures Program Kevin Morgan Director General, Criminal Investigations Directorate Johanne Charbonneau Director, Criminal Investigations Division Stephane Bonin Acting Director General, International and Large Business Directorate Jennifer Ryan Director, Offshore Compliance Division Gina Jelmini Special Advisor, International, Large Business and Investigations Branch Maria Pagliarello Special Advisor, International, Large Business and Investigations Branch Alexandra MacLean Senior Technical Advisor, International and Large Business Directorate Maureen O'Leary 1. ...
In rectifying this redemption to treat it instead as a loan by FHIW Canada to its parent, Newbould J found that there had been a continuing intention for the reciprocal loan arrangement to be tax neutral, and that "the purpose of the … unwind of the loans was not to redeem the preference shares of FHIW Canada … but to unwind the loans on a tax free basis. ... Simmons JA stated that " Juliar … does not require that the party seeking rectification must have determined the precise mechanics or means by which the party’s settled intention to achieve a specific tax outcome would be realized," so that it was sufficient that Fairmont’s "settled tax plan" at the time was to achieve "tax neutrality in its dealings with Legacy and no redemptions of the preference shares. ... Canada, 2015 ONCA 441 under General Concepts – Rectification. ...
BCSC decision
Her Majesty the Queen in Right of the Province of British Columbia v. Her Majesty the Queen in Right of the Province of British >>columbia as Represented by the Minister of Labour and Consumer Services, Employment Standards Branch, and Her Majesty the Queen in Right of Canada, Revenue Canada, Taxation, [1991] 1 CTC 523
Subsection 15(2) provides that “ Notwithstanding any other Act, the amount of a lien and charge and secured debt referred to in subsection(s) (1)...is payable and enforceable in priority over all liens, judgments, charges or any other claims or rights including those of the Crown in the right of the Province...”. ... While the Court of Appeal held that section 224 was a garnishment provision, it was clear in its reasoning that nothing in that section “ (had) the effect of transferring the property of the funds to the Minister or establishing a priority of Revenue Canada's claim”. ...
T Rev B decision
Vir K Handa, Appellant, >>minister of National Revenue, Respondent., [1978] CTC 2256, 78 DTC 1191
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News of Note post
14 November 2022- 11:59pm 1410109 Ontario – Tax Court of Canada finds that a “gratuity” that was required to be paid was subject to HST Email this Content The contract of an incorporated banquet hall with its event customers stipulated: “All Pricing is Subject to 13% HST and 15% Gratuities.” ... He dismissed the taxpayer’s appeal, on the basis that the gratuities were not voluntary, stating: Subsection 133(b) combined with subsection 138(a) … suggests that tips included in an agreement are part of the overall supply of prepared meals, which is subject to HST. … The ETA defines “consideration” as “any amount that is payable for a supply by operation of law.” ... The King, 2022 TCC 141 under ETA – 123(1) – consideration. ...
News of Note post
Boivin JA noted that: “The Judge recognized that the CRA investigators owed the appellants a duty of care … but found that the investigation was not carried out in a manner that could be characterized as negligent and was not motivated by malice or any other improper purpose”. ... Boivin JA found “no reason to disturb the Judge’s findings” – their appeal was dismissed. ... The King, 2023 FCA 12 under General Concepts – Negligence & Fault. ...
25 April 2016- 7:34am Wesdome Gold Mines – Cour du Québec finds that a mine on care and maintenance was a closed mine for CEE purposes Email this Content A company (”Wesdome”) acquired the Kiena mine in Quebec, which had been put on care and maintenance when its reserves had been exhausted over a year earlier, in order that it could extend an existing mine shaft to go under a lake and drill gold targets on its own exploration property to the north. ... ARQ denied CEE deductions under the Quebec equivalent of ITA, s. 66.1(6) – Canadian exploration expense – (c)(vi), which applied to “any expense that may reasonably be related to a mine…that has come into production in reasonable commercial quantities or to an actual or potential extension of such a mine.” ... ARQ, 2016 QCCQ 1504 under s. 66.1(6) – Canadian exploration expense – (c). ...