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The taxpayer is unable to withdraw any amounts from their TFSAs so the conditions of subsection 207.06(1) would not be met and the Minister would have no ability to waive or cancel the tax. 2021 STEP CRA Roundtable – June 15, 2021 QUESTION 11. ...

For those cases where the (re)assessment relies on an anti-avoidance provision of the Act as the primary assessing position, such as section 245 or paragraph 247(2)(b) of the Act, the Canadian Competent Authority will limit itself to forwarding the case to the other competent authority for relief from potential double taxation. 2020 International Fiscal Association Conference CRA Roundtable Question 3 – Draft IC71-17R6, Paragraph 43 We understand that Information Circular IC71-17R5 Guidance on Competent Authority Assistance Under Canada’s Tax Conventions is currently being revised. ...

Reasons: From the moment it is clear that an employee will no longer be required to report for work at the establishment of his employer, he will be deemed to report for work at the employer’s establishment from which the remuneration is paid, as per paragraph 100(4)(a) of the Regulations. 2021 CTF Annual Tax Conference CRA Roundtable Question 10 – Regulation 100(4)(a)- Payroll Deductions and Remittances Due to the pandemic, remote work arrangements are becoming increasingly popular and may remain permanent even after the pandemic ends. ...

Reasons: See below. 2022 International Fiscal Association Conference CRA Roundtable Question 4 – PLOI Late-Filed Penalties and Administrative Relief Where subsection 15(2) or the foreign affiliate dumping rules under section 212.3 would otherwise apply to an amount owing to a corporation resident in Canada (“CRIC”) or certain partnerships, subsections 15(2.11) and 212.3(11) allow for a pertinent loan or indebtedness (“PLOI”) election to be filed in respect of that amount. ...

Reasons: Previous positions, in particular 2011-0401931C6. 2022 STEP CRA Roundtable – June 15, 2022 Question 6. ...

Reasons: Question of fact and law to be determined on a case by case basis. 2022 CTF Annual Conference CRA Roundtable Question 14: Charities – Transfer of Property to a Grantee Organization Background Recently, the Income Tax Act (Act) was amended to permit Canadian registered charities to make disbursements by way of a gift or by otherwise making resources available to a “grantee organization” which is defined to include a person, club, society, association or organization or prescribed entity, but not a qualified donee. ...

Withholding Tax – Dividend “Pays or Credits” Pursuant to subsection 212(2) of the Act, every non-resident person shall pay an income tax of 25 percent on every amount that a corporation resident in Canada pays or credits, or is deemed by Part I or Part XIV to pay or credit, to the non-resident person as a dividend. ...

Reasons: See below. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 13. ...

Reasons: Based on position expressed in CRA document 2022-0943241E5. 2024 CTF Annual Conference CRA Round Table Question 9 – Regulation 105 In CRA document 2022-0943241E5 (2022-0943241E5), the CRA changed the position expressed in document 2008-0297161E5 and provided a new position on the application of Regulation 105 to services billed by a non-resident for services rendered in Canada. ...

Reasons: See complete response. 2014 TEI-CRA Liaison Meeting November 18, 2014 Question E3- Bond Repayments – Non-Financial Institutions Many Canadian taxpayers have issued bonds, debentures and similar obligations. ...