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Income tax considerations are an integral part of the design of flexible employee benefit programs and an important aspect of the selection of benefits by the employee. ... Tax Considerations in the Design of the Overall Flex Program ¶ 5. The concept of the plan year is important to a Flex Program if the program offers employees the choice of both taxable and non-taxable benefits. ... Statutory Considerations ¶ 11. In determining the tax consequences arising from a Flex Program, consideration must be given to whether the Flex Program falls within the definition in subsection 248(1) of a salary deferral arrangement, a retirement compensation arrangement, an employee benefit plan or an employee trust. ...

Table of Contents Assessments or reassessments Issuing a Notice of Assessment Objection process Filing a Notice of Objection Specified persons Input tax credit allocation for financial institutions Late compliance Objection to more than one assessment Restrictions Limitations on objection when waiver signed Limitations on objections Processing a Notice of Objection Consideration of objection Results of decision Appeal of reassessment directly to the Tax Court of Canada Extension of time to object Filing the documentation Duties of the Minister Date of objection if application granted Extension of time limit by the Tax Court of Canada to file a Notice of Objection Conditions to be met for application to be granted Appeal process to the Tax Court of Canada Procedures for hearing appeals Informal Procedure General Procedure Limitations on appeals to the Tax Court of Canada Extension of time limit to appeal to the Tax Court of Canada Applying for extension Filing documentation Conditions to be met Referral to the Tax Court of Canada by Minister and Taxpayer Referral of common questions to the Tax Court of Canada Where the Tax Court of Canada may determine a question Determination and Appeal Time during consideration not counted Federal Court of Appeal Supreme Court of Canada Amounts assessed are payable Security posted Objections and appeals for other taxes Assessments or reassessments 1. ... A person’s threshold amount for any fiscal year is calculated by reference to the total value of the consideration (other than consideration referred to in section 167.1 that is attributable to goodwill of a business) for taxable supplies (other than supplies of financial services, sales of capital real property and zero-rated exports) made in Canada by that person (and any associates) in the immediately preceding fiscal year. ... Consideration of objection 25. Upon receipt of a Notice of Objection, subsection 301(3) provides that the Minister shall reconsider the assessment and vacate or confirm the assessment or make a reassessment. 26. ...

Income tax considerations are an integral part of the design of flexible employee benefit programs and an important aspect of the selection of benefits by the employee. ... Tax Considerations in the Design of the Overall Flex Program ¶ 5. The concept of the plan year is important to a Flex Program if the program offers employees the choice of both taxable and non-taxable benefits. ... Statutory Considerations ¶ 11. In determining the tax consequences arising from a Flex Program, consideration must be given to whether the Flex Program falls within the definition in subsection 248(1) of a salary deferral arrangement, a retirement compensation arrangement, an employee benefit plan or an employee trust. ...

In 2024, the ePayroll Project Team will present a business case and a costed implementation plan to the Government of Canada for their consideration. ... They believe that ePayroll could help increase the efficiency of the tax system, including some specific considerations around T4 slips and Records of Employment. ... The concerns identified by participants include the Government of Canada’s track record of implementing digital platforms, and important considerations around the data security and the protection of private information. ...

Specific situations not accepted for Canadian competent authority negotiation consideration 25. ... However, a taxpayer’s stated intention to pursue MAP relief or not may be taken into consideration by the TSO when deciding whether to enter into an audit settlement or not. Provincial income tax considerations 74. The provinces and territories are not bound by Canadian tax conventions. ...

Specific Situations Not Accepted for Canadian Competent Authority Consideration 26. ... The Canadian Competent Authority will give due consideration to the findings made by the Appeals Branch with regard to the application of Canadian law. 42. ... Provincial Income Tax Considerations 59. The provinces and territories are not bound by Canadian tax conventions. ...

Specific Situations Not Accepted for Canadian Competent Authority Consideration 26. ... The Canadian Competent Authority will give due consideration to the findings made by the Appeals Branch with regard to the application of Canadian law. 42. ... Provincial Income Tax Considerations 59. The provinces and territories are not bound by Canadian tax conventions. ...

Specific Situations Not Accepted for Canadian Competent Authority Consideration 26. ... The Canadian Competent Authority will give due consideration to the findings made by the Appeals Branch with regard to the application of Canadian law. 42. ... Provincial Income Tax Considerations 59. The provinces and territories are not bound by Canadian tax conventions. ...

Refer to Appendix A.6 for a discussion of some specific considerations for dealing with files where there is a NOO or appeal, and when the RTA may be involved in the appeals review process. ... Chapter 5.11.3 discusses procedures for dealing with problems of inadequate records and books. 2.9.0 Contact and communications with the claimant 2.9.1 General considerations All RTAs must know and follow the CRA policy on communications security for protected information. ... The RTA must take into consideration the CRA service standards when planning and conducting a review. ...

Refer to Appendix A.6 for a discussion of some specific considerations for dealing with files where there is a NOO or appeal, and when the RTA may be involved in the appeals review process. ... Chapter 5.11.3 discusses procedures for dealing with problems of inadequate records and books. 2.9.0 Contact and communications with the claimant 2.9.1 General considerations All RTAs must know and follow the CRA policy on communications security for protected information. ... The RTA must take into consideration the CRA service standards when planning and conducting a review. ...