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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. ...

Note 14 Deduct income tax if the payment is considered government financial assistance. But if the payment is considered an inducement to earn business income, do not deduct income tax. ... This amount is considered as employment income. Multimedia Webinar: Special payments and the end of an employee’s employment | 24:44 min. ...

If you are an individual, a corporation, or a partnership and you are accepting payment to prepare returns, you are considered a tax preparer. Note that an employee who prepares tax returns as part of their work duties is not considered a tax preparer. ... For an election to be considered valid, it must be submitted by the due date established in the Income Tax Act. ...

When you sell your principal residence or when you are considered to have sold it, usually you do not have to report the sale on your income tax and benefit return and you do not have to pay tax on any gain from the sale. ... A deemed disposition occurs when you are considered to have disposed of property, even though you did not actually sell it. ... When you change the use of a property, you are generally considered to have sold the property at its fair market value and to have immediately reacquired the property for the same amount. ...

Changes in use of your property When there is a change in use of a property you have, you may be considered to have sold all or part of your property even though you did not actually sell it. The following are some sample situations: You change all or part of your principal residence to a rental or business operation You change your rental or business operation to a principal residence Every time you change the use of a property, you are considered to have sold the property at its fair market value (FMV) and have immediately reacquired the property for the same amount. ... The following are some of the more common situations: Changing all your principal residence to a rental or business property When you change your principal residence to an income producing property, such as a rental or business property, you can make an election not to be considered as having started to use your principal residence as a rental or business property. ...

Situations Situation: You provide an overtime meal or an allowance for an overtime meal to your employee Non-taxable situation Under the CRA's administrative policy, if you provide an overtime meal or an allowance for overtime meal to your employee, the benefit is not taxable if all of the following apply: The allowance or the cost of the meal is reasonable, generally up to $23 including taxes (higher amounts may also be considered reasonable if the meal cost in a specific location is higher or there are other significant extenuating circumstances) Prior year rates Meal rates for previous years Year Flat rate per meal 2023 $23 2022 $23 2021 $23 2020 $23 2019 $17 2018 $17 2017 $17 2016 $17 2015 $17 2014 $17 2013 $17 Your employee works 2 or more hours of overtime immediately before or after their scheduled hours of work Overtime is not frequent and is occasional (generally less than 3 times a week) Example- Meal allowance is not taxable Robert is working on a very large project. ... For example, your employee paid a charge that is not considered reasonable because it is too low. ... References Related Legislation ITA: Section 6 Amounts to be included as income from office or employment ITA: 6(1)(a) Value of any benefit is to be included as income from office or employment ITA: 6(1)(b) Allowance for any purpose CPP: 12(1) Amount of contributory salary and wages ETA: 173 Taxable benefit is considered a supply for GST/HST purposes IECPR: 2(1) Amount of insurable earnings IECPR: 2(3) Amounts not included in insurable earnings IECPR: 2(3)(a.1) Amounts not included in insurable earnings when excluded as income under paragraph 6(1)(a) or (b), or subsection 6(6) or (16) of the ITA What is an allowance What is a reimbursement What is the CRA's administrative policy for the purpose of taxable benefits Cash Near-cash Non-cash Document navigation Next: Determine the tax treatment of payments other than regular employment income Page details Date modified: 2025-03-03 ...