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These and related changes are reflected in the updated CRA Webpage on the “ Pertinent loans or indebtedness (PLOI) ”. ...

Where an election is made, if an amount becomes receivable after 2016 as proceeds of disposition upon the satisfaction of a condition that was part of the agreement under which the disposition was made and the amount would otherwise result in a capital gain for the taxpayer, the amount would under the proposed amendment instead be taxed as it would have been under the ECP regime, with one-half of the gain included in computing the taxpayer's income from a business for a taxation year and the other half … in the taxpayer's capital dividend account. … The taxpayer would need to file this election no later than the filing-due date for the taxpayer's first taxation year that ends after September 30, 2019. ...

The payer can ask for relief on penalties and interest by writing to their tax services office or by submitting a completed Form RC4288, Request for Taxpayer Relief – Cancel or Waive Penalties or Interest. ... Collecting the appropriate forms or equivalent information will help show the payer tried to apply the correct tax rate. ¶ 21. ... (CDS) on securities registered in the name of Cede & Co. Tax on these payments is withheld by CDS based on information it receives from the Depository Trust Company (DTC) and collected by DTC participants. ...

Non-compliance is normally discovered by a Senior Officer Trade Compliance (SOTC) as a result of an audit, examination, verification, or subsequent monitoring activity. … Contravention C353 applies only in cases where customs duties and/or taxes are payable by the importer as a result of the correction. ... Errors discovered during a second or subsequent audit, examination, verification, or monitoring activity that are unrelated to the first penalty assessment will incur only first level penalties. …. ... For example, packaging or assists provisions; (b) formal assessment documents issued by the Canada Border Services Agency (CBSA) to the importer, relating to the imported goods, such as determinations (other than “deemed determinations”), re-determinations, further re-determinations, etc.; … (e) written communication addressed directly to the importer or the importer’s agent from the CBSA such as a national customs ruling, or a trade compliance verification final report; … First Level Penalties … For errors that have occurred as a result of reason to believe criterion (a): First level penalties that are the result of criterion (a) will be assessed on a per issue basis for each issue not corrected within 90 days of having “reason to believe”. ...

After noting that it had “resolved a file regarding a hybrid mismatch arrangement involving the deduction of non-arm’s length interest in a series of transactions that included a forward subscription agreement (outlined in the diagram …) on the basis that paragraphs 247(2)(b) and (d) … and transfer pricing penalties applied,” CRA stated: It is the CRA’s general view that such transactions are undertaken primarily to obtain a tax benefit and that they would not be undertaken by parties dealing at arm’s length. When the CRA finds transactions similar to the example …, the Transfer Pricing Review Committee will be consulted regarding the application of paragraphs 247(2)(b) and (d). ...

4 December 2023 Canadian Tax Foundation Event Announcement-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) safe income policy changes announced on 28 November 2023 are effective for taxation years commencing after that date On December 4, 2023, the Canadian Tax Foundation posted the following message on CRA's behalf regarding CRA’s oral presentation (with slides) made on November 28, 2023 entitled, “ S. 55(2) and Safe Income- Where Are We Now? ”: Pursuant to our presentation on Safe Income at the 2023 Annual Conference on November 28, 2023, all announcements that constitute a change in position will apply prospectively to calculations of safe income for taxation years beginning after November 28, 2023. ...

When funds are: • held on deposit, whether under a TFSA or other arrangement, those amounts are owed by the financial institution (FI) to the depositor and are subject to attachment (RTP); • paid out of a trust arrangement following the direction of the customer or out of an annuity as per the terms of the contract, the funds would be attachable at that time. ... When the TFSA was: • set up as a bank account, send an RTP; • established in any other form, you will need a Writ of Seizure and Sale to seize the funds. ...

. … Digital currency can also be bought or sold like a commodity. … Paragraphs 9 to 32 of Interpretation Bulletin IT-479R, Transactions in Securities, provide information that can help in determining whether transactions are income or capital in nature. ...

CRA Webpage, Enhanced reporting rules for trusts and bare trusts: Frequently asked questions, updated on 14 March 2025-- summary under Subsection 163(5) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(5) s. 163(5) gross negligence penalty could be imposed for failure to file a return 1.10 … Errors or omissions may be identified by the CRA based on a review of the information filed. If the trust is not a listed trust and a person knowingly or under circumstances amounting to gross negligence makes, — or participates in, assents to or acquiesces in, the making of — a false statement or omission on a return required to be filed, or fails to file a return, a penalty may apply under subsection 163(5). ...

. … The school authority’s principal provides a budget to the student council, which is part of the school authority, to provide decorations and authorizes the student council to sell the tickets to the students during school hours. Admission … to the dance is exempt under section 3 …. ...