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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)? ...
Administrative Policy summary
25 March 2021 CBA Commodity Taxes Roundtable, Q.13 -- summary under Subsection 301(3)
Situations where a referral to Audit is discretionary include, but are not limited, to: Where the net tax was estimated due to insufficient books and records; Where the input tax credits were disallowed as the accounting records and/or documentation were not provided; Where the new information provided for review is substantial; Where an on-site visit is warranted to verify certain facts provided by the taxpayer; Where the objection relates to an initial assessment concerning issues of prior years' returns currently being considered by Audit. ...
Administrative Policy summary
7 April 2022 CBA Roundtable, Q.9 -- summary under Subsection 190(1)
Since NewCo thus is not considered to have constructed or substantially renovated the residential complex, it is not a “builder” under paras. ...