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. ¶1.77 is revised to add a reference to paragraph (n) of the term disposition in subsection 248(1) (as added by S.C. 2013, c. 34, s. 358(12)) which states that, among other things, shares of a predecessor corporation held by another corporation that are cancelled on an amalgamation will not generally be considered to have been disposed of as a result of the amalgamation. ... That decision considered whether, because of paragraph 87(7)(d), subsection 78(1) applied to the amalgamated corporation in respect of unpaid interest on a debt that was inherited by the amalgamated corporation from a predecessor corporation. ¶1.59 was added to address the CRA's position regarding whether an amalgamated corporation will, for the purposes of subsections 40(10) and 40(11), be considered to have realized a gain that was deemed under paragraph 111(4)(e) and subsection 111(12) to have been realized by a predecessor corporation. ¶1.60 was added to address the CRA's position regarding the application of the tracing principle under paragraph 20(1)(c) to determine whether an amalgamated corporation would be entitled to deduct under paragraph 20(1)(c) interest paid or payable by the amalgamated corporation on money that was originally borrowed by a predecessor corporation. ¶1.62 was added to address the CRA's position regarding the ability of an amalgamated corporation to file, on behalf of a predecessor corporation, information returns and slips under various provisions of the Act. ¶1.65 (formerly addressed in ¶34 of IT-474R2) has been revised to reflect the CRA's position regarding the collection of a predecessor corporation's tax debts from the amalgamated corporation. ¶1.67 was added to address the CRA's position regarding whether subparagraph 8503(3)(a)(i) of the Regulations will apply following a qualifying amalgamation to include the period throughout which an employee of the new corporation was employed by a predecessor corporation. ¶1.68 (formerly addressed in ¶36 of IT-474R2) has been revised to clarify that a shareholder's exchange of shares of a predecessor corporation for shares of the amalgamated corporation constitutes a disposition for purposes of the Act. ¶1.69 (formerly addressed in ¶36 of IT-474R2) has been revised to include a reference to the circumstances where a share of a new corporation received by a non-resident on an amalgamation constitutes taxable Canadian property under subsection 87(4). ¶1.75 and 1.76 (formerly addressed in ¶40 of IT-474R2) have been revised to add a reference to similar gifting rules contained elsewhere in the Act and clarify that the 87(4) exception applies on a shareholder-by-shareholder basis. ...

Filing allows you to receive any benefits and credits you may be eligible for, such as: goods and services tax (GST) / harmonized sales tax (HST) credit Canada workers benefit Canada child benefit related provincial or territorial payments The tax-filing deadline for most individuals is April 30, 2022 Since April 30, 2022, falls on a Saturday, your return will be considered filed on time in either of the following situations: we receive it on or before May 2, 2022 it is postmarked on or before May 2, 2022 You have until June 15, 2022, to file your tax return if you or your spouse or common law-partner are self-employed. The payment deadline is April 30, 2022 Since April 30, 2022, falls on a Saturday, your payment will be considered paid on time if we receive it, or it is processed at a Canadian financial institution, on or before May 2, 2022. ... Your payment will also be considered paid on time if we receive it, or it is processed at a Canadian financial institution, on or before May 2, 2022. ...

The first thing to know is that the CRA has prescribed rates under section 7306 of the Income Tax Regulations that are considered to be reasonable. ... Scenario – Flat Rate Here the CRA notes that: The allowance is not considered reasonable since it is not connected to kilometres driven. ... Where an employee has driven their automobile for business purposes more than 50% of the time in 2019, they may also be considered to have used their vehicle more than 50% for business purposes in the 2020 and 2021 tax years. ...

When recommendations for corrective action in a prior audit relate to areas considered being at risk, more in depth follow-up audits are included in subsequent CAEB annual business plans. ... The remaining 13 action plans (11%) that were not considered complete relate to three audits: Use of Legislative Enforcement Provisions (May 2006); Tax Information Exchange MOU with Revenu Québec (February 2006); and Information Exchange MOU with Human Resources Development Canada (January 2005). ... In recognition of the lengthy renewal process and the number of stakeholders involved, the progress made in completing these is considered satisfactory. ...

The following is a common scenario: A Canadian resident corporation (CanCo) provides products or services to a non-arm's length non-resident corporation (ForCo) CanCo is considered the tested party Footnote 3 and the transfer price for this transaction is tested using a cost-based method Footnote4 CanCo receives financial assistance from one or more government agencies or programs In calculating the cost base for transfer pricing purposes, CanCo reduces the cost base by an amount equal to the government assistance received Policy When a cost-based transfer pricing methodology is used to determine the transfer price of goods, services, or intangibles sold by a Canadian taxpayer to a non-arm's length non-resident person and the Canadian taxpayer receives government assistance, the cost base should not be reduced by the amount of the government assistance received, unless there is reliable evidence that arm's length parties would have done so given the specific facts and circumstances. ... The following are some of the items that may be considered: identification of all characteristics that are relevant to the market or industry the accounting treatment of the government assistance in both the tested party and any comparable identified, for example, whether the government assistance is deducted from the costs or it is presented separately, Footnote5 since not considering differences such as the accounting treatment can affect profit level indicators whether and to what extent the government assistance is passed on to arm's length customers or suppliers in that particular market or industry when the government assistance is not fully passed on to arm's length customers or suppliers, the manner in which arm's length enterprises operating under similar circumstances would allocate such benefits between them through further enquiry any other relevant information To establish whether a transfer price is consistent with the arm's length principle, the most appropriate transfer pricing methodology must be used. ... For example, when the government assistance can be considered as highly integrated to the operations and significantly affects the economically relevant market conditions, a transactional profit split method may be the most appropriate transfer pricing method. ...

Penalty referrals The application of penalties under subsection 247(3) must be considered in all cases where the total of transfer pricing capital and income adjustments for a taxation year: exceed 10% of gross revenue for the year as calculated under subparagraph 247(3)(b)(i) or exceed $5,000,000 The following steps are involved in making a penalty referral: Taxpayers must be made aware of any transactions that may be subject to a subsection 247(3) penalty. ... At that time, the auditor will advise the taxpayer that the application of paragraphs 247(2)(b) and (d) are being considered with respect to the transactions under review. ... The taxpayer's representations and the additional information will be considered when completing the formal referral report. ...

As well, OCAC considered a CRA proposal for a new committee to examine settlement proposals made at audit stage where those settlements are material or precedent-setting. ... Please refer to Appendix A, which provides the list of "big data" sources considered as part of our review. ... Yours very truly, Colin Campbell, Chair, Offshore Compliance Advisory Committee Appendix A – "Big Data" Sources Considered as Part of OCAC Review Reporting of electronic funds transfers ("EFTs") under section 244.1 of the Income Tax Act ("ITA") Disclosure of transactions with related non-resident entities under section 233.1 of the ITA, reported on the form T106 Disclosure of foreign property held under s. 233.3 of the ITA, reported on the form T1135 Disclosure of information concerning foreign affiliates under section 233.4 of the ITA, reported on the form T1134 The Common Reporting Standard ("CRS") created under the Strasbourg Treaty and providing for automatic exchange of information about financial assets held offshore by Canadian taxpayers (at May 4, 2017 more than 40 jurisdictions, including a number of well-known "tax havens", had agreed to provide such information to Canada on a reciprocal basis, beginning in mid-2018). ...

Special rules may apply for property that was considered taxable Canadian property when you became a non-resident but may no longer be considered taxable Canadian property when you return to Canada. ... Previously deferred tax When you immigrate to Canada, you are generally considered to have disposed of, and to have immediately reacquired, most properties that you own on the date you immigrate. ...

The following expenses are allowable research expenses: salary or wages paid to an assistant the cost of minor equipment and supplies laboratory charges travelling expenses, including meals and lodging, that were incurred while travelling: between your home and the place where you temporarily lived while doing research work from one temporary work location to another on field trips connected to your research work Note If you lived temporarily in a place other than your home, the amount paid for meals, lodging and living expenses is considered a personal expense. ... Royalties Royalties are considered payments received as compensation for using or allowing the use of a copyright, patent, trademark, formula or secret process. ... Note If you are a specified employee and your employer made contributions to your EPSP, you may have to pay tax on the amount that is considered an excess amount. ...

Note Qualifying transfers, exempt contributions and specified distributions are not considered in the calculation of contributio n room. ... Management fees related to a TFSA trust and paid by the holder are not considered to be contributions to the TFSA. ... How to know your TFSA contribution room The TFSA contribution room is the total amount of all of the following: the TFSA dollar limit of the current year any unused TFSA contribution room from previous years any withdrawals made from the TFSA in the previous year Note Qualifying transfers, exempt contributions and specified distributions are not considered in the calculation of contribution room. ...