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Income Tax Technical News No. 22, 11 January 2002-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission ...

Excise and GST/HST News- No. 95 under "-- summary under Subsection 156(2) Summary Under Tax Topics- Excise Tax Act- Section 156- Subsection 156(2) // www.cra-arc.gc.ca/E/pbg/gf/rc4616/README.html ">Form RC4616 – Simplified filing procedures concerning existing elections for nil consideration" 8 April 2015 Specified members of a qualifying group that have existing elections, each with a different effective date that is before January 1, 2015, have the following two options for filing Form RC4616: Under simplified procedures developed by the CRA, specified members of a qualifying group that have existing elections, each with a different effective date that is before January 1, 2015, now only need to file one Form RC4616 indicating December 31, 2014 as the effective date (covering all members instead of each filing separately). ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.8-- summary under Section 133 Summary Under Tax Topics- Excise Tax Act- Section 133 s. 133 determines time of acquisition for ITC purposes In finding that input tax credits can generally be claimed by a builder for invoices issued subsequent to the date of self assessment on substantial completion and first occupancy of a multiple unit residential complex (a “MURC”) for work done by suppliers for goods and services sold/installed performed prior to the first tenant move-in, CRA stated: Under section 133, a supply of property or a service is generally considered to be made at the time that the agreement to provide the property or service is entered into. ... The time at which the consideration for a supply of property or a service becomes due under section 152 … does not impact the time at which the supply is considered to be made, nor does that time impact the purpose for which the recipient of the supply acquired the property or service. … ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.10-- summary under Subsection 256.2(7) Summary Under Tax Topics- Excise Tax Act- Section 256.2- Subsection 256.2(7) it would be “fair” to adjust the rebate when assessing under s. 191(3) Notwithstanding the posted question’s wording, CRA apparently addressed a different question of how to secure an increased NRRPR rebate when CRA is proposing to assess to increase the amount of GST/HST self-assessed under s. 191(3) based on an increased fair market value for the property. CRA responded: [S]ubsection 296(2.1) only applies to unclaimed rebate amounts and cannot apply in cases where the person has claimed the allowable rebate in an application filed before the day the notice of assessment is sent to the person per paragraph 296(2.1)(b). … Furthermore, the registrant would be precluded from claiming and submitting a new rebate application as only one application per rebate per matter can be made pursuant to subsection 262(2). … The registrant could request a re-assessment or consideration in the course of the audit of the NRRPR to take into account the change in GST/HST payable on the FMV provided the time limitation for assessing the rebate has not expired. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.14-- summary under Paragraph 296(1)(a) Summary Under Tax Topics- Excise Tax Act- Section 296- Subsection 296(1)- Paragraph 296(1)(a) CRA will not grant ITCs when it assesses following an audit but without receiving any GST/HST return What is the position of the CRA on overturning a notional notices of assessment (NNOAs) when the GST return is filed? CRA responded: The purpose of issuing the notional assessments is to encourage the taxpayer to file their GST/HST returns. … [B]inding NNOAs will be issued on completed exams where full records were reviewed but: No returns were provided This process only applies to NNOAs raised subsequent to a GST/HST Trust Accounts Examination, where an on-site review of books and records was completed and the registrant did not file a return. ... Non-binding NNOAs can be overridden at any time with a filed return by the registrant. … For binding assessments, the CRA will not include ITCs as [it] does not want to make a decision on behalf of the registrant on when to claim their ITCs. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.18-- summary under Subsection 273(4) Summary Under Tax Topics- Excise Tax Act- Section 273- Subsection 273(4) back-dated election generally permitted if the parties had been treating one as in place Joint venture participants, who had not made a joint venture election, purchased real estate collectively through a representative who was registered for GST/HST purposes. ... Generally, if the conditions of the … Election … have been met, and the parties have treated their transactions as if the election had been valid (which is supported by agreements/invoices) and the parties are otherwise compliant with the CRA, Audit will allow this election to be backdated. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.8-- summary under Subsection 141.01(2) Summary Under Tax Topics- Excise Tax Act- Section 141.01- Subsection 141.01(2) purpose of acquisition is assessed at time agreement is entered into In finding that input tax credits can generally be claimed by a builder for invoices issued subsequent to the date of self assessment on substantial completion and first occupancy of a multiple unit residential complex (a “MURC”) for work done by suppliers for goods and services sold/installed performed prior to the first tenant move-in, CRA stated: Under section 133, a supply of property or a service is generally considered to be made at the time that the agreement to provide the property or service is entered into. ... The time at which the consideration for a supply of property or a service becomes due under section 152 … does not impact the time at which the supply is considered to be made, nor does that time impact the purpose for which the recipient of the supply acquired the property or service. … ...

IC86-4R3 "Scientific Research and Experimental Development"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...

IT-151R4 "Scientific Research and Experimental Development Expenditures"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...

IT-151R4 "Scientific Research and Experimental Development Expenditures"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...