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Canada has also recently ratified the multilateral Convention on Mutual Administrative Assistance in Tax Matters, which further expands our international information sharing network. ...

The CRA’s rulings and interpretations of Canada’s income tax laws are based on the Income Tax Act, the Income Tax Regulations, all related statutes, and the Income Tax Conventions which Canada has with other countries. ...

Its clients were impoverished, the vast majority being “convention refugees.” ...

A charity’s internal planning documents explicitly confirm that it will oppose a political party that takes a different view on a certain policy issue, by holding a public demonstration in front of the building where the party is gathering for its annual convention. ...

Nevertheless, there are some particular situations where the amount reported on line 108 may include the following: 100% ITCs for the GST/HST paid or payable on the charity’s purchases of, or improvements to, capital property or real property for use primarily (more than 50%) in the charity’s commercial activities, including the deemed GST/HST payable when capital property is brought into a participating province for use primarily in its commercial activities; any ITC for the GST/HST paid or payable on the charity’s purchase of, or improvement to, real property based on the percentage of use of the real property in the charity’s commercial activities (must be more than 10%) and for which it filed Form GST26, Election or Revocation of an Election by a Public Service Body to Have an Exempt Supply of Real Property Treated as a Taxable Supply, that is effective the day the property is acquired; any ITC for the GST/HST considered paid on the deemed purchase of real property based on the percentage of use of the property in the charity’s commercial activities (must be more than 10%), where the election (Form GST26) takes effect on a day other than the day the property was acquired by the charity or the day the charity becomes a registrant; 100% ITCs for the GST/HST paid or payable on goods that the charity acquired, imported, or brought into a participating province that will be sold by a person acting as an agent (including a billing agent), or an auctioneer and agent, for the charity; 100% ITCs for the GST/HST paid on goods imported by the charity on behalf of a non‑resident person for use exclusively in the charity’s commercial activities and sold when the charity was acting as an agent, or auctioneer and agent, for the non‑resident person; 60% of the total of the GST/HST adjustments (for example, for price reductions and rebates for foreign conventions and for artistic works produced for export) or of point‑of‑sale rebates for the provincial part of the HST that the charity gave in the reporting period (no amount should be included for any Ontario First Nations point‑of‑sale relief credited in the reporting period as the charity may claim this amount by filing Form GST189, General Application for Rebate of GST/HST, using code 23); 60% of the total tax amount of a tax adjustment note issued by the charity in the reporting period to a pension entity; the GST/HST adjusted, refunded, or credited in a credit note issued by the charity in the reporting period for tax charged in excess of the GST/HST collectible on certain supplies of property or services; GST/HST adjustments relating to bad debts written off during the reporting period in respect of sales of capital property or real property; the GST/HST adjusted, refunded, or credited in a credit note issued by the charity in the reporting period in respect of sales of capital property or real property; GST/HST adjustments relating to the GST/HST new housing rebate where the charity is a builder and paid or credited the rebate to an individual purchasing new housing; and 100% ITCs that the charity was entitled to claim and that it carried forward from a reporting period when it did not have to use the net tax calculation for charities. ...

These obligations stem, among others, from the Income Tax Act, Excise Tax Act, the Access to Information Act, the Privacy Act, the Canada Pension Plan and tax conventions. ...

This principle is articulated by the Organisation for Economic Co-operation and Development (OECD) in Article IX of the OECD Model Convention on Income and Capital and is the international consensus approach to transfer pricing determination for member countries of the OECD. ...

All downward transfer pricing adjustments that should be directed to CASD will be managed in accordance with current version of Information Circular IC71-17, Competent Authority Assistance Under Canada’s Tax Conventions. 3. ...

The Director of CASD is supported by a division of approximately 50 employees structured as follows: Four Transfer Pricing MAP/APA sections consisting of 36 tax and economics specialists, working exclusively on MAP and APA cases concerning resolution of double taxation (attribution/allocation cases); One MAP Technical section consisting of 9 tax and legal specialists, working exclusively on non-transfer pricing MAP cases (other cases concerning taxation not in accordance with a convention); One Program Support section consisting of 5 employees working on procedural, reporting, monitoring and other program-related functions. ...

Tax Convention. The treaty contains robust safeguards to ensure the Internal Revenue Service will treat taxpayer information confidentially, and use the information solely to administer tax laws. ...