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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. ...

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. ...

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. ...

This is an important consideration for demonstrating the extent to which the issues were communicated to the claimant by the FR, and the efforts to work with the claimant to resolve these issues. ... The FR needs to take into consideration the CRA service standards when planning and conducting a review. ... Consideration of penalties must be discussed with the FRM in all cases. ...

Income tax considerations The following sections outline the income tax implications of common transactions involving crypto-assets. ... GST/HST considerations Based on your cryptoasset activities, you may have to register for and start charging the GST/HST. ... The calculation excludes consideration attributable to the sale of goodwill of a business, supplies of financial services, and supplies by way of sale of capital property. ...

Lease intervals – Deemed supplies of real property Where a supply of property is made by way of lease, license or similar arrangement for consideration that is attributable to a period (referred to as a "lease interval") that is the whole or a part of the period during which possession or use of the property is provided under the arrangement, a separate supply of the property for separate consideration is deemed to be made by the supplier and received by the recipient for each lease interval. ... Examples- When the province in which the greatest proportion of the Canadian rights can be used cannot be determined Example 1- Consideration of $300 or less An individual purchases a movie pass that provides ten adult admissions to any of a movie chain's five cinemas situated in Nova Scotia and New Brunswick. ... Examples- When the supply can be used otherwise than only primarily in participating provinces or non-participating provinces Example 1- Consideration of $300 or less An individual purchases a movie pass that provides ten adult admissions to any of a popular movie chain's locations. ...

Nominal consideration 21. Subsection 141.01(1.1) provides that, for purposes of determining the extent of use in subsections 141.01(1.2) to (3), supplies for nominal consideration are treated the same as supplies for no consideration. The term “nominal consideration” is not defined in the Act. A determination of whether a supply is made for nominal consideration will be based on the facts of the individual case. ... For example, under subsection 153(1), where the consideration or a part of the consideration is expressed in money, the value of the consideration or that part is deemed to be equal to the amount of the money and, where the consideration or part is other than money, the value of the consideration or that part is deemed to be equal to the fair market value of the consideration or that part at the time the supply was made. 23. ...