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If the taxpayer cannot demonstrate to the CRA’s satisfaction the absence of retroactive tax planning, base erosion and profit shifting strategies, or double non-taxation, the auditor will … recommend the request not be accepted …. ... Therefore, in order for a downward transfer pricing adjustment to be considered appropriate, repatriation must be carried out within 90 days of signing a repatriation agreement (see … TPM-02R ….) 27. ... Appendix A – Examples Example of double non-taxation being addressed through foreign reporting or under MAP 3. ...

Excise and GST/HST News- No. 97 17 November 2015-- summary under Section 7 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule V- Part II- Section 7 Acupuncture services – need for patient relationship Only services rendered by a practitioner of acupuncture to an individual within a practitioner-patient relationship are exempt from the GST/HST under the exemption for acupuncturists. This means that the practitioner must be a direct care provider of the patient and a relationship involving personal interaction between the practitioner and the patient must have been established for the exemption to apply. … Overlapping exemptions (e.g., dentist/acupuncturist) …[I]n some provinces a dentist may perform acupuncture services within the scope of practice for a dentist. ...

Example 2 – Goods imported into Canada In a claim period, a registrant PSB resident in New Brunswick purchases commercial goods in the United States and imports them into New Brunswick for use by the PSB exclusively (90% or more) in its commercial activities in that province. The goods are valued at $15,000 (including duties), on which the PSB pays $750 in GST ($15,000 × 5%) to the CBSA at the time of importation of the goods. ...

T4068(E) Guide for the Partnership Information Return (T5013 Forms)-- summary under Subsection 96(1.01) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(1.01) S. 96(1.01) special allocation is made at the end of the regular partnership taxation year Line 350 – Other adjustments … Paragraph 96(1.01)(a) does not require that partnership income or loss be calculated immediately after a member leaves the partnership. ...

. … The amount of the forgivable loan will equal 50% of the monthly gross rent payable by the impacted small business tenant during the 4-month period. ... Generally, the remaining part of the refund or adjustment (that is, the difference between the amount of the rent reduction and the amount of the forgivable loan) must be borne by the commercial property owner. … No GST/HST collectible by CMHC on forgivable loans GST/HST implications There is no GST/HST applicable with respect to payments received by the commercial property owners from CMHC under the CECRA program. … The forgivable loans provided by CMHC under the CECRA program are exempt supplies of financial services. … Requirement to follow s. 232 re rent reductions Application of GST/HST to refunds or adjustments of the gross monthly rent paid or payable The rent reduction agreement … has the effect of reducing the amount of consideration payable for a taxable supply of real property made by way of lease, licence or similar arrangement …. … [P]ursuant to a rent reduction agreement, a commercial property owner agrees to subsequently reduce an impacted small business tenant’s monthly gross rent payable by at least 75% for the 4-month period. Pursuant to section 232 … in this case where a commercial property owner agrees to refund or credit an amount of GST/HST already collected, or agrees to adjust the GST/HST applicable to the reduction of the monthly gross rent payable, the commercial property owner must issue a credit note, meeting the prescribed requirements that are set out in the Act, to the impacted small business tenant. ...

Example 14 – Seized property used by creditor A registrant PSB resident in Saskatchewan is not a charity to which subsection 225.1(2) (net tax calculation for charities) applies. ... The PSB is deemed to have collected GST of $1,250 ($25,000 × 5%) on the fair market value of the office equipment. ...

… As some bare trusts may be uncertain about the new requirements, the CRA is adopting an education-first approach to compliance and providing relief to bare trusts by waiving the penalty payable under subsection 162(7) of the Income Tax Act for the 2023 tax year in situations where the T3 Return and Schedule 15 are filed after the filing deadline for reasons other than gross negligence. … This proactive relief is for bare trusts only and only for the 2023 tax year. ...

“Consultation on Reforming and Modernizing Canada's Transfer Pricing Rules” 6 June 2023-- summary under Subsection 247(1.3) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(1.3) The profit allocations that were accepted in Cameco were reached based on relationships created by intra-group contractual arrangements, notwithstanding Cameco Switzerland's minimal factual substance and Cameco Canada's assumption of related risks through the provision of performance guarantees to Cameco Switzerland – so that Cameco Switzerland was left with an allocation of income that did not correspond to the value it created through its underlying economic activity. ... Similarly, it would have retained some autonomy as to the disposition of its product over time. … [T]he overall result of the application of proposed subsection [247](2.02) would be the recognition by Canco of significant additional income in line with its functional profile …. ...

IT-273R2, "Government Assistance- General Comments," para. 15-- summary under Subparagraph 12(1)(x)(iv) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x)- Subparagraph 12(1)(x)(iv) Timing of recceipt of benefit of tax credit ¶ 17. Federal and provincial tax credits and deductions from tax which are in the nature of inducements, or which are received as assistance for the cost of property or an expense, are included in income under paragraph 12(1)(x) in the year received unless one of the exceptions discussed in ¶ 8 applies. ...

Amounts in Cdn$/functional currency Table 1 – Overview of allocation of income, taxes and business activities by jurisdictions For electronic filing, all amounts must be stated in Canadian dollars [except that]... ... The reporting entity discloses in Table 3 – Additional Information that it is reporting in one of the qualifying currencies notwithstanding that no election has been made by the reporting entity pursuant to paragraph 261(3)(b) of the Act. ... Payments received from other CEs that are treated as dividends in the payor’s tax jurisdiction should be excluded. … “Revenues-Related Party” should be read as the aggregate amount of revenues generated from transactions between constituent entities listed in Table 2, for each relevant tax jurisdiction. ...