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Administrative Policy summary
8 March 2018 CBA Commodity Taxes Roundtable, Q.7 -- summary under Money
8 March 2018 CBA Commodity Taxes Roundtable, Q.7-- summary under Money Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Money CRA reviewing whether crypto-currencies are "money" Does the position in 2013-0514701I7, that “Virtual currencies, such as Bitcoins, are not considered to be a currency … [so that] using Bitcoins to purchase goods or services would be treated as a form of barter transaction” still hold, or (given that the definition of “money” is not restricted to the listed items and includes “money”) does CRA consider the purchase and sale of crypto-currencies to be an exempt supply of a financial service (specifically, of money)? ...
Administrative Policy summary
8 March 2018 CBA Commodity Tax Roundtable, Q.10 -- summary under Subsection 225.2(2)
CRA, considered this suggestion to be quite at odds with the scheme of the SAM formula rules, which required the SLFI to compute and remit an amount which was quite distinct from the tax paid to its suppliers. ...
Administrative Policy summary
7 March 2019 CTF Seminar on GAAR: Brian Ernewein on GAAR – Past and Future -- summary under Subsection 245(4)
Finance has considered: Whether a GAAR penalty should be introduced (the potential downside is that this might have a deleterious effect on the jurisprudence, i.e., fewer Crown wins) Explicitly incorporating economic substance into GAAR. ...
Administrative Policy summary
AD-19-02 Obtaining Information for Audit Purposes 2019-03-21 -- summary under Paragraph 231.1(1)(a)
A taxpayer with large unexplained tax reserves may be considered to be at a higher risk of non-compliance. ...
Administrative Policy summary
AD-19-01 Audit Agreement and Waiver of Objection Rights Guidelines 2019-02-19 -- summary under Subsection 169(2.2)
The relevant International Advisory Services Section Manager of the International Tax Division must be consulted in all cases where an audit agreement is being considered for a transfer pricing issue. ...
Administrative Policy summary
28 February 2019 CBA Roundtable, Q.2 -- summary under Section 17
. … 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. ...
Administrative Policy summary
GST/HST Memorandum 20-8 “Educational Services Made to a Non-resident” December 2019 -- summary under Section 18
. … While stand-alone industry safety courses may be beneficial, and in some cases a job requirement, on their own they would not be considered to lead to an occupation. ...
Administrative Policy summary
GST/HST Memorandum 20-7 “Second-language Instruction” December 2019 -- summary under Section 11
. … [I]f the portion of the business’s total annual revenues that is derived from language course fees/tuition or that can be attributed to instruction in these courses falls to 50% or less during the following fiscal year, the business would no longer be considered to be operated primarily to provide instruction in languages in the next fiscal year. ...
Administrative Policy summary
GST/HST Notice 304 “GST/HST Pension Plan Rules for Master Trusts” April 2017 -- summary under Subsection 172.2(3)
This deemed tax paid would be considered to be an eligible amount upon which the designated pension entity may claim a rebate. ...
Administrative Policy summary
27 February 2020 CBA Roundtable, Q.15 -- summary under Subsection 191(3)
Does CRA agree that where the “income method” is used to determine the FMV of a MURC, that the FMV thereby derived should be considered to be inclusive of GST/HST, so that such GST/HST should then be backed out for purposes of coming to a reduced corrected FMV for purposes of s. 191(3)? ...