Search - 辐射监测仪 校准

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 …. ...

(b) … If a particular supply meets the requirements of both sections 17 and 18, the supplier must make an election under both sections to ensure that the supply will not be exempt under either of these sections. … [However] sections 17 and 18 are generally mutually exclusive and would not apply to the same supply of a membership. ... (c) … It would be unwieldy to require a supplier to complete a separate form in respect of every supply. Therefore, the Minister has approved a form that will allow a supplier to make an election indefinitely, until the supplier chooses that it no longer wants the election to apply … [by] complet[ing] Section D of the relevant form. … On completion of Section D, the supplier is no longer considered to have made an election in respect of any supplies of memberships as of the effective date of the revocation. ...

The test still has a gatekeeping function – avoidance still must be one of the “main” purposes – before getting to the “misuse or abuse” analysis, but this represents a more modern approach to avoidance transaction rules, and gets around some of that analytical uncertainty in situations where there are multiple purposes, leading to an artificial exercise in picking the “winner” from among those purposes. ...

8 September 2017 Interpretation 180362-- summary under Section 133 Summary Under Tax Topics- Excise Tax Act- Section 133 supply made when master sales agreement entered into S. 144 provides that “a supply of goods that have been imported … but have not been released [by the CBSA] before the goods are delivered … to the recipient of the supply, shall be deemed to be made outside Canada,” so that even if the vendor is a registrant, it is not required to charge GST/HST. ... In this regard, CRA stated: Under section 133, the supply of the goods is deemed to be made when the agreement for the supply of the goods is entered into. … The relevance of the timing of when a supply is made under section 133 to the application of section 144 is reflected in the wording of the definition of "specified supply" of goods under subsection 178.8(1) … [which] distinguishes between a supply of goods that are imported after the supply is made, and a supply of goods that have been imported in circumstances in which section 144 deems the supply to have been made outside Canada. … ...