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ETA 280.1: • Failure to file penalty applies (1% x $10,000) + (1% x $10,000 x ¼ x 5 months) Note: Although the return was due on Feb 28, 2007, the Budget Implementation Act provides that for purposes of section 280.1, returns due and outstanding prior to March 31, 2007, are deemed to be required to be filed on March 31, 2007. ... GEN – TCC: On December 23, 2004, the CMPA filed an appeal before the TCC. ... Q.43- Excise Taxes – End-User Refunds Please comment on the status of this review. ...

The answer to questions # 1 and #2 would generally be the same for purposes of Division II, III or IV tax. ... Q.28- Zero-Rated Exports – Services (i) An estates lawyer prepares a will for a non-resident individual. ... Assume in this case that the Canadian does qualify under subsection 185(1) – i.e. the financing transaction relates to its commercial activities within CCRA’s policy guidelines – notably P-094 and P-108). ...

Tax on Split Income – Excluded Shares CRA Response Q6. Tax on Split Income – Business Sale CRA Response Q7. ... Change in FMV – NRRPR CRA Response Q11. CRA My Business Account – View filed numbers CRA Response Q12. ... RC4188 – What you should know about audits, and IC98-1R7 – Tax Collections Policies. ...

REAL PROPERTY Q.6- Real Property – Goodwill Answer Q.7- Real Property –Section 261 Answer Q.8- Real Property – Section 194 Answer C. ... Is the rationale that the employee is considered part of the non-resident corporation – and therefore the contracting party – or does the example have a broader application? ... Q.52-Rulings/Technical Memorandum (a) Application or Advance Ruling – what is the difference? ...

Email this Content 15 May 2024 IFA Roundtable Q.1 – PPT and Treaty threshold for 5% withholding Preliminary Response Q.2 – Entity classification of Lux. SCS and SCSp Preliminary Response Q.3 – Cash pooling arrangements and notifiable transactions Q.3(a) Preliminary Response Q.3(b) Preliminary Response Q.3(c) Preliminary Response Q.3(d) Preliminary Response Q.3(e) Preliminary Response Q.3(f) Preliminary Response Q.3(g) Preliminary Response Q.4 – Procedure for late-filed PLOI election Preliminary Response Q.5 – Late-filed PLOI election and statute-barring Preliminary Response Q.6 – Blanket PLOI election Preliminary Response Q.7 – PPT and reduced dividend withholding Situation (a): Same Rate Situation (b): Non-Treaty Country in Ownership Chain Preliminary Response Situation (a) Situation (b) This provides the text of written questions that were posed, and summaries of the CRA oral responses, at the CRA Roundtable held on May 15, 2024 at the International Fiscal Association (Canadian Chapter) conference in Montreal. ... There are two segments in that description – thin capitalization and Part XIII tax. ...

Voluntary disclosures – wash transactions and section 236.1 CRA Comments Q.3. ... Voluntary disclosure – tax services offices CRA Comments Q.6. Voluntary disclosures – 10 YEAR RULE CRA Comments Q.7. ... FOREIGN SEMINARS – ARE SERVICES IN PART IN CANADA Summary of Facts / Background A US Company, registered for GST, provides seminars in the US. ...

HST place of supply rules – legal services CRA Comments Q.25. HST place of supply rules – sales of tangible personal property CRA Comments Q.26. ... Summary of Facts A supplier (“ Québec Co. ”) manufactures widgets for its customer (“ Ontario Co. ”). ... Une de ces conditions est que le fournisseur « possède des preuves, que le ministre estime acceptables, de l’exportation du bien par l’acquéreur ». ...

Those shares would not qualify as shares of a “ specified class ”, in particular because of paragraph 256(1.1)(b), which requires that the shares not carry voting rights. ... Official Response 10 October 2024 APFF Roundtable Q. 8, 2024-1028891C6 F- Définition du terme « automobile » Q.9 – S. 13(5.2) application to optioned automobile An individual, after having paid $12,500 in lease expenses during the first 48 months of an automobile lease, exercises the option under the lease to acquire the automobile for $15,000, at a time that its FMV is $20,000, then immediately sells it for $20,000. ... CRA Responses (a) Essentially, section 67.3 limits all or part of the “actual lease charges ” paid or payable for a passenger vehicle that a taxpayer may deduct in computing income for the year. ...

Additionally, the Progress Tracker which is available in My Account and My Business Account, provides taxpayers with the date that the objection was assigned to an appeals officer for the low & medium-complexity, ITA & GST categories. ... Q.14(e) Would the CRA consider adding to My Account / My Business Account / Represent a Client the ability to request assistance with issues that cannot be done directly online? ... Q.19(b)- Time for “T” slips to appear in My Account / Represent a Client Members have noted long delays for slips to appear on My Account / Represent a Client. ...

Email this Content 17 May 2023 IFA Roundtable Q.1 – Cross-border charges re stock-based compensation Preliminary Response Q.2 – Ukraine/Russia reporting requirements Preliminary Response Q.3 – T1134 disclosure of dividends Preliminary Response Q.4 “Special tax benefit” exclusion under Barbados Treaty Preliminary Response Q.5 – Canadian home offices and US employers Preliminary Response Q.6- Art. ... Where goods are produced or services are performed – again, this will be affected by the nature of the individual’s activities and USco’s business will be relevant in weighing this factor. ... S. 253(a) deems USco to be carrying out business in Canada if it “produces, grows, mines, creates, manufactures, fabricates, improves, packs, preserves or constructs, in whole or in part, anything in Canada ….” ...