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7 April 2022 CBA Roundtable, Q.1-- summary under Subsection 165(3) Summary Under Tax Topics- Income Tax Act- Section 165- Subsection 165(3) an Appeals Officer can (and may) increase the reassessment under appeal CRA stated that it has the authority under ETA s. 301(3) (equivalent, although not identical, to ITA s. 165(3)) to further increase a reassessment that has been objected to (for example, if a second valuation prepared for the Appeals Officer produced an even higher valuation) – but indicated that “[a]ny upward adjustment must be approved by the Appeals Officer’s manager or the Chief of Appeals.” ...

. … 1.51 While paragraphs 87(2)(l.3) and 88(1)(e.2) prevent the deferral from being lost, it may not be reasonable to conclude that the property was acquired to replace a former property. ...

In accordance with subsection 301(1.5), where a person has filed a Notice of Objection to an earlier assessment and the Minister makes a particular assessment under subsection 301(3) … [under s. 301(3)] as a result of the Notice of Objection, subsection 301(1.4) does not limit the right of the person to object to the particular assessment in respect of an issue that was part of the particular assessment and not part of the earlier assessment. ...

CRA Webpage, Enhanced reporting rules for trusts and bare trusts: Frequently asked questions, updated on 14 March 2025-- summary under Paragraph 150(1.2)(a) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.2)- Paragraph 150(1.2)(a) Scope of 3-month trust 2.5 … The following trusts are considered to have been in existence for less than three months at the end of the taxation year: Trusts that ceased to exist during the particular taxation year, at a date which is less than three months after the trust was created Trusts that were created less than three months before the end of the particular taxation year. ...

. … 26. A sole proprietor, such as a teacher or a coach, who has a contract with a vocational school to provide a service of instruction as one of the sole proprietor’s business revenue streams is not considered a vocational school for purposes of that contract. This is because the self-employed person supplies the service to the vocational school …. ...

Typical out-of-pocket expenses not generally incurred as agent that a registered supplier may charge a client include …: office supplies, if they are associated with the service being performed by the supplier for the client air travel local transportation, such as a taxi parking hotel or other accommodation per diem amounts, such as meals car rentals and gasoline an automobile allowance, where the supplier’s personal vehicle is used in the performance of the service Expenses incurred as agent When a supplier incurs an out-of-pocket expense as a client’s agent … the client is considered to be the recipient of the supply. ...

The trust is disqualified by the existence of a power to encroach on the capital or income for the benefit of persons other than the spouse or common-law partner, prior to their death – or by a discretion of the trustee to allocate the trust’s income or capital among members of the deceased taxpayer’s family during the life of such individual. 1.27 – 1.29 Spousal discretion. ...

. … CRA can accept and process that second GST189 as it was filed in a subsequent calendar quarter and the rebate claimed is in respect of a new matter. ...

. … The CRA is currently working on streamlining the process to expedite the processing of these requests by improving internal efficiencies…. ...

Gouin-Toussaint, September 1989 Revenue Canada Round Table (Dec. 89 Access Letter, ¶1040)-- summary under Subsection 256(5.1) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(5.1) A public corporation and a private corporation plan to each acquire ½ of the common shares of a third corporation ("Opco"). ...