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T2059 Election on Disposition of Property by a Taxpayer to a Canadian Partnership-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) Filing instructions (different where co-ownership) Mail one copy of this election and related schedules (as specified), completed by the transferor as follows: – to the tax centre of the transferor – on or before the earliest date on which any party to the election has to file an income tax return for the tax year in which the transaction occurred (due date). This due date must consider any election under subsection 25(1) or 99(2) – separately from any other return • When many transferors elect to transfer the same property (co-ownership) or many members of the same partnership elect to transfer their partnership interests, the elections will be processed together and should be filed: – to the tax centre of the transferee – on or before the due date – by a designated transferor to file all of the completed forms for each transferor, together with a list of all of the electing transferors. This list should contain the name, address and social insurance, trust account or business number of each transferor and of each member of the transferee – separately from any other return ...

26 August 2019 Comfort Letter- “Advantage”: Exclusion for Investment Management Fees-- summary under Subparagraph (b)(i) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (b)- Subparagraph (b)(i) where RRSP or TFSA fees (described in s. 20(1)(bb)) are paid by the annuitant or holder [If] investment management fees of registered plans … are paid directly by the holder/annuitant using funds outside of the plan, the resulting indirect increase in the value of the plan assets might be viewed as an advantage … if one of the main purposes is to benefit from the tax-exempt status of the plan. Even so, we have no tax policy concerns with respect to the payment of investment management fees directly by the annuitant/holder of the registered plan. … Generally, the direct payment of fees results in either a net loss, or negligible gain, for the plan holder. We are therefore prepared to recommend … clarifi[cation] that the payment by a controlling individual (as defined in subsection 207.01(1)) of investment management fees that pertain to a registered plan does not constitute an advantage … [and] [s]pecifically … that paragraph (b) of the definition "advantage" in subsection 207.01(1) be amended [respecting 2018 and subsequent taxation years] such that it does not apply to payments by a controlling individual of a registered plan, not exceeding a reasonable amount, of fees described in paragraph 20(l)(bb) …. ...

This requirement … is outlined in … “Protocole D’entente” signed August 30, 1990 between the CRA and RQ. … [S]ection 4.1 … states: Canada and Quebec recognize that, with respect to the transfer to Quebec of administrative responsibilities of the GST, they will continue to assume their duties under the Official Languages Act and the Charter of the French Language respectively, with respect to communications with the public, including corporations and the services provided to them. … [S]ection 4.2 … states: … Quebec declares that, subject to the provisions of the Charter of the French Language, it will communicate with taxpayers in the administration of the GST, either orally or in writing, in English or French, to the same extent that such taxpayers may communicate with or receive services from Canada in those languages in accordance with the Official Languages Act. ...

Schedule 510 Ontario Corporate Minimum Tax (2009 and later tax years)-- summary under Subsecion 60(1) Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Taxation Act 2007- Section 60- Subsecion 60(1) Filing required if CMT credit carryforward • A corporation not subject to CMT in the tax year is still required to file this schedule if it is deducting a CMT credit, has a CMT credit carryforward, or has a CMT loss carryforward or a current year CMT loss. … Filed with T2 • File this schedule with the T2 Corporation Income Tax Return. Reporting of deduction for reorganization gains [Line 342: deduct:] Accounting gain on transfer of property to a corporation under section 85 or 85.1 of the federal Act *** … Note … ***A joint election will be considered made under subsection 60(1) of the Ontario Act if there is an entry on line 342, and an election has been made for transfer of property to a corporation under subsection 85(1) of the federal Act. ...

Limitation Period on Discretion for Relief of Penalties and Interest ¶ 13. ... The taxpayer must comply with such requests within the stipulated timeframes…. iii) Penalty ¶ 38. A disclosure must involve the application, or potential application of a penalty. … In the event a penalty does not apply, the taxpayer cannot seek relief through the VDP. … iv) One Year Past Due ¶ 39. ...

The federal part of the HST paid in respect of the supply of the goods is $1,100 ($2,860 × 5/13). ... The provincial part of the HST paid in respect of the supply of the goods is $1,760 ($2,860 × 8/13). ... The PSB self-assesses the amount of $440 ($22,000 × 2%) on Form GST489. … This amount is included in subparagraph 259(1)(a)(i) when calculating the provincial non-creditable HST charged in respect of the goods for the claim period.... ...

Your taxable revenues and expenses are as follows: Taxable revenues: Gallery admissions $20,000 Sales from gift shop $5,000 Total $25,000 GST collected ($25,000 × 5%) $1,250 Taxable purchases: Contracted services (maintenance) $3,000 Utilities $1,500 Ventilation system $9,200 Computer equipment $2,000 Gift shop inventory purchases $2,500 Catering services for fundraising dinner $3,500 Total $21,700 GST paid on purchases ($21,700 × 5%) $1,085 Net tax calculation Step 1 Enter $750 on line 105 of your GST/HST return (60% of the $1,250 GST collected). ... ITC 5% × ($9,200 + $2,000) = $560 Step 3 The amount you calculate in Step 1 less the amount you calculated in Step 2 equals your net tax before any rebates. Net tax $750 – $560 = $190 Enter this amount on line 109. You would also be entitled to claim a PSB rebate of the remaining GST/HST paid. ...

Example 7 – Service supplied in a participating province In a claim period, a non-registrant PSB acquires software programming services from a supplier in Ontario for $35,000. ... The PSB pays $4,550 in HST ($35,000 × 13%). … The PSB is required to self-assess tax at the rate of 2% on the value of the consideration for the supply of the services purchased in Ontario (2% being the difference between the 10% rate of the provincial part of the HST in Prince Edward Island and the 8% rate of the provincial part of the HST in Ontario) to the extent (expressed as a percentage) that the services are used in Prince Edward Island. The PSB self-assesses tax of $140 ($35,000 × 2% × 20%) on Form GST489…....refer to NOTICE 266.... ...

Example 11 – Adjustment to net tax for rental property on becoming a small supplier division In July, a registrant PSB resident in Ontario that has a monthly reporting period prepays the monthly rent of $1,500 plus HST for six months (July through to December) for the building in Ontario used by its division in commercial activities. The total amount of rent prepaid is $9,000 ($1,500 × 6 months) plus $1,170 in HST ($9,000 × 13%). ... The PSB is required to add to its net tax an amount of $585 ([$1,500 × 13%] × 3), which is accounted for by the PSB on line 104 (or on line 105 if filing electronically) of its October GST/HST return. ...

GST/HST Memorandum 13.5 Non-creditable Tax Charged January 2017-- summary under Subsection 261.1(1) Summary Under Tax Topics- Excise Tax Act- Section 261.1- Subsection 261.1(1) Application to public service body Example 22 – Goods acquired in a participating province and removed to another participating province In a claim period, a non-registrant PSB purchases goods in New Brunswick for $19,000, on which it pays $2,850 in HST ($19,000 × 15%). ... The federal part of the HST paid in respect of the purchase is $950 ($2,850 × 5/15). ... The provincial part of the HST paid in respect of the purchase is $1,900 ($2,850 × 10/15). ...