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Information on calculating remissions is described in Appendix H of IC 70-6R11 Advance Income Tax Rulings and Technical Interpretations 2021 STEP CRA Roundtable – June 15, 2021 QUESTION 8. ... The service standard for a Ruling is 90 business days commencing with the receipt of all information required from the client as outlined in Appendix A – Ruling Request Checklist of Information Circular IC 70-6R11, Advance Income Tax Rulings and Technical Interpretations (footnote 2) (IC 70-6). ... Remission of the service fee will be granted when the Ruling is issued, or the Pre-ruling Consultation is completed, subsequent to its service target date, as set out in Appendix H – Remissions of IC 70-6. ...

Information on calculating remissions is described in Appendix H of IC 70-6R11 Advance Income Tax Rulings and Technical Interpretations 2021 International Fiscal Association Conference CRA Roundtable Question #9 – Income Tax Rulings Directorate- Remissions The fees charged by the Canada Revenue Agency (“CRA”) for providing an advance income tax ruling or a supplemental ruling (“Ruling”), and a consultation in advance of a Ruling (“Pre-ruling Consultation”), are governed by the Service Fees Act (footnote 1). ... The service standard for a Ruling is 90 business days commencing with the receipt of all information required from the client as outlined in Appendix A – Ruling Request Checklist of Information Circular IC 70-6R11, Advance Income Tax Rulings and Technical Interpretations (footnote 2) (“IC 70-6”). ... Remission of the service fee will be granted when the Ruling is issued, or the Pre-ruling Consultation is completed, subsequent to its service target date, as set out in Appendix H – Remissions of IC 70-6. ...

Can the CRA confirm the following: Situation 1 – Individual A has designated their three siblings as equal beneficiaries under the FHSA in accordance with provincial law. ... Situation 2 – Individual A has designated their estate as beneficiary under the FHSA in accordance with provincial law. ... Situation 2 – The deemed distribution under proposed paragraph 146.6(17)(c) will result in an income inclusion of $30,000 to the estate under subsection 146.6(14) in Year 2. ...

Reasons: See above 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 12. ... We would also mention that, recently, in documents # 2010-0377601R3 and 2012-0456221R3, we have issued favourable subsection 129(1.2) rulings on proposed post-mortem estate planning transactions. 2013-048036 Daniel Wong ...

If there is any change to this administrative practice in the future, information will be made available. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 14. ... Earlier this year, the CRA released two new forms – the T3 INNS3, Trust Instalment Voucher and the T3AO, Trust Amount Owing Remittance Voucher. ...

Position: General comments Reasons: See below 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 15. ... " 2 Organisation for Economic Co-operation and Development, Forum on Tax Administration SME Compliance Sub-Group, January 2012. 3 Budget 2012: "The Canada Revenue Agency continues to modernize its operations and reduce red tape to enhance services to Canadians while reducing its overall costs. … In addition, the Agency will leverage the expertise of tax professionals to improve the effectiveness of its operations. ...

STEP CRA Roundtable – June 10 2016 Question 13. Filing obligation for 75(2) trust holding non-income producing property The “Who Should File” section of the T3 Guide states: “A T3 return must be filed if the trust is subject to tax, and any one of the following conditions applies. The trust: … holds property that is subject to subsection 75(2) of the Act” This seems to suggest that a reversionary trust is required to file a T3 Trust Income Tax and Information Return for a year regardless of whether the trust has tax payable, or whether property subject to subsection 75(2) earns any income or profits, or generates a capital gain. ...

CALU CRA Roundtable- May 2012 Question 9 – Group Sickness and Accident Insurance Plans and ROP Background In TI 2009-0314871E5 issued March 3, 2011, CRA indicated that if there are other benefits provided under a disability policy, and if those benefits are not accident and sickness insurance benefits, the plan would not qualify as a group sickness and accident insurance plan (GSAIP). ... Weir / Nerill Thomas-Wilkinson 2012-043576 ...

Consistent with the Supreme Court of Canada’s comments in Shell Canada Ltd v the Queen, [1999] 3 S.C.R. 622 (SCC), in absence of sham or a provision to the contrary, the better view is that no portion of the swap payment from Canco to NRco can be considered interest, and therefore, withholding tax does not apply. 2020 International Fiscal Association Conference CRA Roundtable Question 2 – Withholding tax on mismatched swap payments A Canadian resident taxpayer (Canco) enters into a Swap Agreement (Swap Agreement) with a non-arm’s length non-resident company (NRco). ... Anna Flisfeder / Gwen Moore September 15, 2020 2020-085274 ...

Raisons: See Supplemental Guidance on International Tax Issues published by the CRA on April 1, 2021. 2021 International Fiscal Association Conference CRA Roundtable Question 1 – COVID 19 and CRA Guidance Post September 2020 In January 2021, the Organisation for Economic Co-Operation and Development (“OECD”) came out with detailed guidance on interpreting tax treaties in light of COVID-19, (particularly with respect to determining “residency” and “permanent establishment” under tax treaties). ... While the CRA has indicated that they will be providing new guidance focused on individuals, will the CRA also extend its guidance for corporations that expired in September 2020 – given that the pandemic has not yet been resolved and the global travel restrictions remain in place? ...