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Of course, the screening process technically begins even earlier, with the audit team’s decision on whether to refer the matter to Headquarters in the first place, so that it is possible that some things get missed – which is to say that, from a taxpayer perspective, things could certainly be worse! ... We had a new communique out to our auditors, which should be on our website fairly soon, that talks about what we call audit agreements – that’s a settlement at audit stage – what’s involved and when we engage that process. ... Written communication is not an effective way to address certain emergent Questions – such as whether particular words or statements under consideration are being taken out of context. ...

Process for inital contact – do requests go to taxpayer, representatve, or both? ... Process for initial contact – do requests go to taxpayer, representative, or both? ...

In the situation described above, will CRA consider that UKco has a permanent establishment in Canada under Article 5 of the Canada – U.K. ... ASIC Miners ASIC miners, on the other hand, are designed and optimised to perform a single task – mine crypto-assets. ... (iii) Part II Section 3A – Surplus Accounts – 4. Upstream Loan Rules (Table) Column 2 of the Table requires reporting entities to identify if a specified debtor (as defined in subsection 90(15)) owes an amount to the foreign affiliate (or a partnership of which the foreign affiliate was a member) at any time during the reporting period. ...

D4- Provincial allocation disputes At one time, the CRA employed a formal process — the Tax Re-Allocation Committee (TRAC) — for resolving provincial allocation disputes. ... E3- "Normal open-market" purchase in s. 39(3) 2014-0550401C6 E – 2014 TEI Liaison Meeting, Q. ... E6- S. 115.2(2)(b)(i)(B)- Forco share issuance to affiliated Canco 2014-0550421C5 E – 2014 TEI-CRA Liaison Meeting – Question E6 – Non-Resident Carrying on Business in Canada Where a non-resident engages a Canadian investment manager, the activities of the investment manager may cause the non-resident to be carrying on business in Canada for Canadian tax purposes. ...

Such assets might be disposed of before the acquistion – or immediately after the acquisition. ... XXVI and Annex A, there were (per Susan) very few cases of ultimate double taxation, the presence of arbitration has speeded (by approximately 1/3) the resolution of Mutual Agreement Procedure cases due to the incentive for the two competent authorities to grapple with the more difficult issues on a more expeditious basis – and (per Susan) the resulting habit of greater efficiency also has speeded the handling of MAP files for third countries. The dialogue in a MAP case will be continued for so long as it can be carried forward (per Patricia) – and even if arbitration has commenced, the two authorities will continue to try to resolve the dispute consensually. ...

Physical cash-pooling involves actual transfers of cash within accounts in the cash pool; notional cash-pooling does not – there can be positive and negative balances as long as the overall balance is zero or positive. ... Thus, for the purposes of computing the numerator of the fraction – the net income of the foreign affiliate from the FAPI business – it is necessary to first identify the activities that would form part of FAPI business and, when that is reasonably determined, then the gross income under the foreign tax rules from that FAPI business is to be computed, with that amount then being reduced by the total amount of deductions that are allowed under the foreign tax law and claimed by the foreign affiliate in the taxation year that may reasonably be regarded as directly applicable only to the FAPI business; this amount should also be reduced by the prorated amount of deductions (again allowed under the foreign tax law and claimed by the foreign affiliate) that would not reasonably be regarded as applicable to either the FAPI business or any other income-generating activities, such as overhead or head office expenses. ... That fraction is multiplied by the total foreign tax paid by the foreign affiliate to arrive at the amount of foreign tax that may be regarded as applicable to FAPI – that figure is then converted into Canadian dollars pursuant to s. 261. ...

. … Official Response 16 June 2014 STEP Roundtable, Q. 3, 2014-0522971C6 See summary under 93.3. ... The initiative also required all paid preparers of individual income tax returns who are not CPAs, attorneys or enrolled agents to pass a competency exam and complete annual continuing education requirements related to tax law and professional conduct. … [I]n January 2013… the U.S. ... By registering tax preparers, the CRA will be able to fulfill the goal of the RTPP – to identify which tax preparers are making errors and to work with them to prevent these errors before the tax return is filed. ...

The preamble to s. 104(4) states that the deemed disposition dates apply to each property of the trust – that is, the dates are not tied to specific properties. S. 104 might not apply in the circumstance, because s. 108(1) – “trust” – (g) generally provides that the s. 104(4) will not apply to a trust in which all interests have vested indefeasibly. ... The result is the same as it was in the first scenario for the person who is just the shareholder in that s. 15(1.4)(c) won’t apply, for the same reason – the amount of the wages are already included in the shareholder’s income – in this case, the shareholder-employee’s employment income. ...

Therefore using Bitcoins to purchase goods or services would be treated as a form of barter transaction ….” ... Under s. 225.2(2), the SLFI is required to determine its net tax under the formula [(A-B) x C x (D/E)]- F + G (SAM Formula). ... S. 228(2.3) provides that “where a person who is a [SLFI] is required to file a final return … (a) the person shall calculate … the net tax … (b) where the net tax of the person… is a positive amount, the person shall remit that amount to the Receiver General on or before the day the final return for the reporting period is required to be filed.” ...

.), substantially for the reasons offered in the T.C.C. judgment (" Alco Dispensing ")], M.N.R. v. ... The Petit Robert de la langue française defines the term "actif" [“asset”] as “l’ensemble des biens ou droits constituant le patrimoine “ ["all the property or rights constituting the patrimony"]. ... In a self‑assessing tax system such as that provided for in the Act, taxpayers should have confidence that the Minister is administering and enforcing the same tax laws in the same way for everyone (pp. 33-34 and 68). [26] Practically, this constrains the Minister to assess a taxpayer in accordance with the facts of the matter ⸺ here, the transactions ⸺ and the law (CIBC World Markets Inc. v. ...