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December 2017 GST/HST Memorandum 16.5 – Voluntary Disclosures Program-- summary under Subsection 281.1(2) Summary Under Tax Topics- Excise Tax Act- Section 281.1- Subsection 281.1(2) Effective 2018 This memorandum applies to Voluntary Disclosures Program applications received on or after March 1, 2018…. ... Track 1 – GST/HST wash transactions 12. Category 1 specifically provides relief for applications involving GST/HST wash transactions that are eligible for a reduction of penalty and interest under the policy set out in GST/HST Memorandum 16-3-1, Reduction of Penalty and Interest in Wash Transaction Situations. … Track 2 – General program 13. ... Track 3 – Limited program 15. In general terms, Category 3 provides limited relief for applications that disclose non-compliance where there is an element of intentional conduct on the part of the registrant or a closely related party including, but not limited to, situations where: GST/HST was charged or collected but not remitted; efforts were made to avoid detection (for example, participation in underground economy); the disclosure is made after an official CRA statement regarding its intended specific focus of compliance (for example, the launch of a compliance project or campaign) or following broad-based CRA correspondence (for example, a letter issued to registrants involved in a particular sector about a compliance issue); there had been deliberate or wilful default or carelessness amounting to gross negligence. 16. ...

GST/HST Memorandum 3-3-4, Place of Supply in a Province – Real Property, August 2024-- summary under Subsection 136.1(1) Summary Under Tax Topics- Excise Tax Act- Section 136.1- Subsection 136.1(1) Supply of building for each lease interval is where the building is situate Example 4 – Lease of real property in a particular province Pursuant to a lease agreement, a company in New Brunswick leases a commercial office building situated in New Brunswick to a company in Ontario for a period of 10 years. ...

GST/HST Memorandum 3-3-3, Place of Supply in a Province – Tangible Personal Property, August 2024-- summary under Section 3 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule IX- Part II- Section 3 Where Manitoba purchaser itself retains the common carrier and PEI vendor merely contacts the carrier when ready, the place of supply is that of legal delivery in PEI Example 3 – Delivery of a good by a common carrier retained by the purchaser A manufacturer in Prince Edward Island sells a good to a wholesaler in Manitoba. ...

Excise and GST/HST News – No. 119, April 2025-- summary under Section 9 Summary Under Tax Topics- Excise Tax Act- Schedules- Schedule VI- Part II- Section 9 list of the particulars that should be recorded by a supplier of contact lenses or eyeglasses (if it does not have the prescription) The Supply of Prescription Eyeglasses and Contact Lenses … Alternative of retaining particulars of prescription (pp. 1-2) In Excise and GST/HST News No. 113 CRA indicated that the simplest way for a supplier to demonstrate that a supply of contact lenses or eyeglasses was made to a consumer pursuant to a valid prescription or assessment record, as required by s. ...

GST/HST Memorandum 3-3-4, Place of Supply in a Province – Real Property, August 2024-- summary under Section 136.2 Summary Under Tax Topics- Excise Tax Act- Section 136.2 Proration of single option to buy two properties based on the properties’ relative values Example 3 – Option to purchase real property in different provinces A builder in Ontario is advertising a new home for sale in Ontario for $1,000,000. ...

Frequently Asked Questions – Temporary Wage Subsidy for Employers 30 March 2020 CRA Webpage-- summary under Subsection 153(1.02) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1.02) 1. Overview of wage-subsidy COVID-19 response The Temporary Wage Subsidy for Employers is a three-month measure that will allow eligible employers to reduce the amount of payroll deductions required to be remitted to the … CRA …. 2. ... This includes reducing remittances that may fall outside of the application period for the wage subsidy (after June 19, 2020). … 8. ...

Clause 6(2)(b)(i)(C) …and … 8(b)(i)(C) … further provides that if the supplier does not obtain a home or business address in Canada of the recipient in the ordinary course of its business, but in the ordinary course of its business the supplier obtains another address in Canada of the recipient, the supply is made in the province in which the address that is most closely connected with the supply is located. 54. [In this context] … there is no requirement for the address of the recipient to be an address at which the recipient is located. 55. The types of addresses that could fall under this … Rule … could include an address of the recipient such as a billing address. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.6-- summary under Subsection 284.1(2) Summary Under Tax Topics- Excise Tax Act- Section 284.1- Subsection 284.1(2) late filing a financial institution return is not particularly relevant to the imposition of an ETA s. 284.1 penalty When asked about the application of the ETA s. 284.1 penalty to an unfiled return, and whether a zero dollar line item triggers the minimum penalty amount of $1,000, CRA stated: Where an information return that was not filed on time is subsequently filed, and the correct amount reported on the particular line is zero … there would be no penalty under subsection 284.1(1) based on the formula for calculation the penalty in that subsection. … Where an information return that was not filed on time is subsequently filed, and the correct amount reported on the particular line is zero … a penalty under subsection 284.1(2) would be calculated based on the formula in that subsection. ...

Alexandra MacLean, "CRA Audits of Large Corporations- The view from ILBD" under Responses to recent adverse decisions – Univar, 27 November 27 2018 CTF Annual Conference presentation.-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) Univar GAAR doctrine entails looking at reasonable alternative transactions Univar found that the result of the cross-border surplus-stripping transactions before it could have been equally accomplished if the non-resident indirect purchaser of Canco had instead been able to access the surplus of Canco by using a subsidiary Buyco with high paid-up capital. CRA indicated that Univar signifies that, in the context of a consideration of the general anti-avoidance rule, there can be an examination of what the taxpayer could have done versus what the taxpayer did do – but CRA is examining what limitations should be placed on this approach. For example, the mooted alternative must have been commercially reasonable – something that the taxpayer could actually have done. ...

26 February 2019 Toronto CRA & Tax Professionals Seminar-- summary under Subsection 247(2) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2) BEPS has not substantially affected CRA's transfer-pricing practices CRA comments relating to the mooted BEPS impact on CRA transfer-pricing practices included: BEPS Actions 8 to 10 did not effect substantial changes, i.e., the underlying principles are the same. ... Canada has not adopted the simplification measure concerning low-value-added intragroup services – so that, rather than accepting a flat markup on intragroup service-charges because of the OECD guidance, CRA will continue to rely on IC87-2R to govern intragroup pricing until adoption of a new measure. ... The Canadian penalty regime is not more rigorous than Action 13 – instead it is that CRA's audit process is more rigorous than in most jurisdictions. ...