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26 February 2019 Toronto CRA & Tax Professionals Seminar-- summary under Paragraph 247(4)(a) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(4)- Paragraph 247(4)(a) penalties typically imposed where missing or unsubstantiated analysis CRA stated: Penalties are usually imposed for failure to have accurate and complete contemporaneous documentation respecting the ss. 247(4)(a)(iv) to (vi) matters (regarding the underlying analysis). ... 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. ...

Objections and appeals — Frequently asked questions, forms and publications-- summary under Subsection 12(10) Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Land Transfer Tax Act- Section 12- Subsection 12(10) Tax payable even if objected to … Do I have to pay the amount assessed that is in dispute while the objection is under review? ...

GST/HST Memorandum 3-3-5 “Place of Supply in a Province – General Rules for Intangible Personal Property” January 2025-- summary under Canadian Rights Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 2- Canadian Rights Limitation in situs of use determined by the agreement or by factual limitations 14. The general place of supply rules can require a determination of the extent, if any, to which the use of the Canadian rights is limited to one or more provinces, which may generally be found in the terms of the agreement for the supply governing the use of the rights. … 15. ...

GST/HST Technical Information Bulletin B-108, Changes to GST/HST Rules for Pension Plans – New Section 157 and Amendments to Section 172.1, 5 February 2014-- summary under Subsection 172.1(9) Summary Under Tax Topics- Excise Tax Act- Section 172.1- Subsection 172.1(9) Overview of Element A in the A/(B-C) formula Element A The amounts to be included in element A are described in subsection 172.1(9) in paragraphs (a) through (f) of that element. ... An employer that was a selected qualifying employer or a qualifying employer (explained later in this bulletin) in the preceding fiscal year (and thus relieved from accounting for tax under the deemed taxable supply rules in that year) must also include in the calculation any amounts that would have been included in element A had the employer not been a selected qualifying employer or a qualifying employer in that year. … Overview of Element B in the A/(B-C) formula Element B The amounts to be included in element B are described in subsection 172.1(9) in paragraphs (a) through (c) of that element. ... An explanation on TANs is included in Part V of GST/HST Notice 257, The GST/HST Rebate for Pension Entities. … Overview of Element C in the A/(B-C) formula Element C The amounts to be included in element C are described in subsection 172.1(9) in paragraphs (a) and (b) of that element. ...

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 19-- summary under Subsection 26(1) Summary Under Tax Topics- Excise Tax Act- Regulations- Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations- Subsection 26(1) purchasing debt securities not lending/meaning of trust or loan corporation Would a person whose sole business activity is to purchase conditional sales contracts or mortgages be considered to be a trust and loan corporation? ... …In addition…a corporation whose principal business is the lending of money or the making of loans is a loan corporation. … Where a third party purchases or receives an assignment of a conditional sales contract, the third party would generally not be considered to be lending money or making a loan to the assignor of the conditional sales contract. ...

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 35-- summary under Section 17 Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 17 fee for training session or seminar was for IPP Conference example ABC Co hosts a two day conference on the latest developments within a particular field and engages various experts to present papers and lead workshops at the conference. ... The place of supply rules in sections 6 and 7…would generally be relevant…. … Generally, to determine that a particular supply is a service, it would have to be established based on a complete set of facts that the predominant element of the supply is a service…. ...

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 35-- summary under Subsection 6(1) Summary Under Tax Topics- Excise Tax Act- Regulations- New Harmonized Value-Added Tax System Regulations- Section 6- Subsection 6(1) fee for training session or seminar was for IPP Conference example ABC Co hosts a two day conference on the latest developments within a particular field and engages various experts to present papers and lead workshops at the conference. ... The place of supply rules in sections 6 and 7…would generally be relevant…. … Generally, to determine that a particular supply is a service, it would have to be established based on a complete set of facts that the predominant element of the supply is a service…. ...

Eligibility of Work for SR&ED Investment Tax Credits Policy, 24 April 2015-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Regarding the second step of CRA's two-step analysis of SR&ED ("determine if there is SR&ED" and "determine the extent of eligible work"), CRA states: Support work must be the following: It must be commensurate with the needs of the basic research, applied research, or experimental development work undertaken in Canada. ...

IT-126R2, "Meaning of 'Winding-Up' ", March 20, 1995-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition 4. ... Evidence confirming that proposed dissolution would generally require proof that the requirements for dissolution, as outlined in 4 above, have been met. … 9. ...

CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 21-- summary under Section 7 Summary Under Tax Topics- Excise Tax Act- Regulations- Electronic Filing and Provision of Information (GST/HST) Regulations- Section 7 reporting RITC for wrong province results in penalty Will CRA assess penalties under s. 284.01 where a large business inadvertently reports the wrong province to which a recaptured input tax credit relates (e.g., Ontario rather than B.C.), but this error does not result in an increase to the net input tax credits that should be reported? ... As the penalty calculations in section 7 of the Regulations are based on the difference between the RITCs that should have been reported for each particular province in a specified return for a reporting period and the RITCs that were actually reported, or un-reported, for that particular province in that return, the over-reported amount of RITCs for Ontario would result in a negative penalty calculation… that…[p]ursuant to section 125… is deemed to be nil. … However, the un-reported amount of RITCs for British Columbia would result in a penalty amount equal to a minimum of 5%, to a maximum of 10%, of that un-reported amount, where the amount remains unreported for 5 complete months or more. ...