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Toronto Centre Canada Revenue Agency & Professionals Group Newsletter, Vol. 13-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) Issue 4, December 2014 …Pilot project: Pre-ruling consultations Framework The Income Tax Rulings Directorate (ITRD) is offering…[t]he pre-ruling consultation [which] will allow the Applicant to discuss with ITRD professionals (the ITRD Representatives) any unique, new technical issue that is critical to the structuring of seriously proposed transactions in advance of submitting a ruling request. ... ITRD …Subject to operational requirements, ITRD will schedule a teleconference within 3 weeks from the date on which a complete Application is received. … Agreement to participate in a pre-ruling consultation does not constitute the commencement of the ruling process and it will not give priority if an advance income tax ruling request is ultimately submitted. ... Determination The ITRD Representatives will inform the Applicant of whether ITRD would consider the issue further in the context of an advance income tax ruling. … Any comments provided by ITRD Representatives will not be binding on the Canada Revenue Agency. ...

May 2019 CPA Alberta CRA Roundtable, GST Session – Q.7-- summary under Section 285 Summary Under Tax Topics- Excise Tax Act- Section 285 a gross negligence penalty generally should not apply to a genuine misinterpretation of the ETA or where no false statement has been made Where GST/HST returns are unfiled due to administrative bookkeeping or accounting oversight, is the penalty applicable? CRA noted that given that “a false statement be made in a return, application, form, certificate, statement, invoice, or answer,” not filing a return is insufficient grounds for the penalty, but then stated: Kion … suggests that even where no return has been filed, a gross negligence penalty under section 285 is permissible. ... Similarly, CRA noted that “the fact that a registrant solely fails to respond to an audit contact letter or fails to provide records on time is generally insufficient grounds to apply gross negligence penalties” – and that the s. 284 penalty instead could be applied where there was failure “to provide any information or document when and as required.” ...

T400A Notice of Objection – Income Tax Act-- summary under Subsection 165(1) Summary Under Tax Topics- Income Tax Act- Section 165- Subsection 165(1) Collection action – We usually postpone collection action on amounts in dispute until 90 days after we sent the Minister's decision on your objection. ...

GST/HST Memorandum 3-3-5 “Place of Supply in a Province – General Rules for Intangible Personal Property” January 2025-- summary under Subsection 136.1(1) Summary Under Tax Topics- Excise Tax Act- Section 136.1- Subsection 136.1(1) Application of place-of-supply rules can change at the beginning of each lease interval 19. … [S]eparate supplies of intangible personal property that are deemed to be made for each lease interval may be subject to the GST or the HST at a different rate, to the extent that those supplies are deemed to be made in a different province based on the application of the place of supply rules for intangible personal property. ...

GST/HST Memorandum 3-3-5 “Place of Supply in a Province – General Rules for Intangible Personal Property” January 2025-- summary under Clause 8(1)(b)(i)(B) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 8- Paragraph 8(b)- Subparagraph 8(b)(i)- Clause 8(1)(b)(i)(B) Example 21 A lawyer operating an Ontario law firm and living in Quebec purchases access to an online law website by a subscription from an Ontario content provider and, consistent with the ordinary business practice of the provider, provides the law firm address as the business address and the lawyer's home address as the billing address. The Ontario contracting address is the one most closely connected with the supply and the IPP may be used in Ontario – so that the province of supply is Ontario. ...

Mandatory disclosure rules – Guidance, 15 August 2024 CRA Webpage-- summary under Contractual Protection Summary Under Tax Topics- Income Tax Act- Section 237.3- Subsection 237.3(1)- Contractual Protection Reportable Transactions Contractual protection “Standard representations, warranties and guarantees between a vendor and purchaser, as well as traditional representations and warranties insurance policies, that are generally obtained in the ordinary commercial context of mergers and acquisitions transactions to protect a purchaser from pre-sale liabilities (including tax liabilities), are not expected to give rise to reporting requirements for reportable transactions” “A reporting obligation would not arise solely in respect of contractual protection in the form of insurance that is integral to an agreement between persons acting at arm’s length for the sale of a business where it is reasonable to conclude that the insurance protection is intended to ensure that the purchase price paid under the agreement takes into account any liabilities of the business immediately prior to the sale and the insurance is obtained primarily for purposes other than to obtain a tax benefit from the transaction or series”- and "[f]or greater clarity, the contractual protection hallmark would not arise solely where the insurance or indemnity is based on the actions or inactions of a person to achieve a tax result. ... “[T]ax return insurance would not constitute contractual protection insofar as the insurance is extended to a taxpayer’s filings generally, and does not contemplate any particular transaction or series of transactions entered into by a taxpayer ….” ... A public-company acquiror “obtains specific contractual covenants and/or indemnities from the Target and the significant shareholders of the Target … that are intended to ensure the Target and/or the significant shareholders do not take certain steps that may cause the bump denial rules to apply … This could also apply in a private corporation context.” ...

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 22. ... CRA stated: The definition of "service" in [s.] 123(1)… is broad, and… encompasses the assumption of the obligations of another party in return for consideration from the other party. … In this case, the Purchaser has supplied a service to the vendor and GST/HST is collectible on the consideration payable for the supply of the service. ...

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 22. ... CRA stated: The definition of "service" in [s.] 123(1)… is broad, and… encompasses the assumption of the obligations of another party in return for consideration from the other party. … In this case, the Purchaser has supplied a service to the vendor and GST/HST is collectible on the consideration payable for the supply of the service. ...

CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 35. ... The types of additional services that may be include are discussed in … GST/HST Notice 224 under "Ancillary property and services. ...

IT-126R2, "Meaning of 'Winding-Up' ", March 20, 1995-- summary under Subsection 88(1) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1) 4. ... Evidence confirming that proposed dissolution would generally require proof that the requirements for dissolution, as outlined in 4 above, have been met. … ...