Subsection 200(1)
Administrative Policy
26 June 2018 External T.I. 2018-0746971E5 - Bonus received after death of employee
A retired employee, who had a right to receive a bonus payment (a restricted share unit) in 2017 and in 2018, died in 2017 which, under the terms...
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| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | employment income recognized in year of entitlement notwithstanding T4 reporting not until payment | 201 |
6 October 2017 APFF Roundtable Q. 2, 2017-0709001C6 F - T4A filing obligation
Respecting whether a s. 162(7) penalty will be imposed for failure to provide a T4A to a service provider even if the provider’s invoice bear a...
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| Tax Topics - Income Tax Act - Section 162 - Subsection 162(7) | "temporary" policy for not applying penalties for failure to issue T4As to independent contractors | 126 |
21 November 2016 Internal T.I. 2016-0675761I7 F - Obligation de produire un T4A
2013-0507171I7 F indicated that where a producer paid fees under a contract of service with the corporation of an incorporated performing artist...
7 October 2016 APFF Roundtable Q. 1B, 2016-0652761C6 F - T4A filing
In light of the wording of ITA s. 153(1)(g) and Reg. 200(2), there is a broad range of inappropriate circumstances where the issuance of a T4A is...
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| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(g) | limited exceptions to T4A reporting | 148 |
30 March 2016 Internal T.I. 2014-0547931I7 F - Voyages offerts par une compagnie
2012-0472211I7 concerned a Canadian company which provided free annual trips to southern resorts to high-performing brokers and sales agents of...
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| Tax Topics - Income Tax Act - Section 9 - Nature of Income | full value of incentive trips, including business portion, included in income of recipient personal corporations | 110 |
31 March 2017 External T.I. 2016-0675221E5 - T4A
Is an amount paid to an individual as rent for the use of a facility is considered an amount paid as a fee, commission or other amount for...
9 March 2017 External T.I. 2016-0677351E5 - Withholding on remuneration paid to a non-resident
A corporation resident in Canada pays salary and director’s fees to a shareholder who is U.S.- resident individual, who is not in Canada in the...
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| Tax Topics - Income Tax Regulations - Regulation 104 - Subsection 104(2) | non-resident director attending all Canadian board meetings by phone or internet is not subject to withholding | 186 |
24 September 2015 External T.I. 2013-0495611E5 - Withholding on incentive payments to non-residents
A Canadian resident manufacturing corporation ("Canco") pays the non-resident employees, of non-resident dealers selling its products outside...
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(iii) | no withholding on payments based on sales warranties sold by dealers | 126 |
| Tax Topics - Income Tax Regulations - Regulation 100 - Subsection 100(1) - Remuneration | no withholding on payment to non-resident employee of 3rd party | 143 |
16 March 2015 External T.I. 2014-0521791E5 - Estate Trustee Fees
CRA noted that if fees earned from an estate by a lawyer were income from a business, the estate would be required to prepare and file a T4A form.
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Office | trustee fees of a lawyer from office if appointed on personal grounds | 197 |
7 November 2014 External T.I. 2014-0535591E5 F - Revenu travailleur autonome
A corporation incurs various expenses for the benefit of its representatives, who are self-employed, such as travel expenses, conferences,...
7 March 2014 Internal T.I. 2013-0507171I7 F - Obligation de produire un T4A
A producer who retains the services of an incorporated performing artist is required under the terms of the collective agreement with the Union...
18 October 2013 External T.I. 2013-0494441E5 - Amending a T4A
What circumstances give rise to the need to amend a T4A? CRA stated:
Section 200… requires the payer to report the correct amount paid. If the...
22 March 2011 External T.I. 2010-0391131E5 F - Gains ouvrant droit à pension - RPC/RRQ
Should Box 26 of the T4 slip be zero or should it be left blank where an employee is under 18 years of age during the entire taxation year in...
28 April 2011 Internal T.I. 2011-0394301I7 F - Obligation de l'employeur - feuillet T4 modifié
When asked what an employer should do when it discovers that T4 slips issued by it incorrectly showed an automobile benefit, CRA stated:
[T]he...
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.2) | procedure for employee to request correction of incorrectly reported T4 benefit | 204 |
28 March 2013 External T.I. 2012-0460031E5 F - Prime pour partager chambre à deux
Employees of a construction services company (the “Employer"), who are working at a remote construction facility, are provided accommodation and...
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | allowance paid by 3rd-party customer to employees re double-occupancy rooms was taxable | 144 |
30 April 2013 External T.I. 2013-0479451E5 F - Paiement forfaitaire rétroactif admissible
An individual sued his former employer on the basis that the employer had wrongfully terminated the employee’s long term disability benefits. ...
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| Tax Topics - Income Tax Act - 101-110 - Section 110.2 - Subsection 110.2(1) - Specified Portion | lump sum received respecting wrongful termination of disability payments that should have been paid in prior years was eligible | 208 |
6 December 2012 External T.I. 2012-0461711E5 F - Paiements indirects / Indirect payments
A producer who retains the services of an incorporated performing artist is required to pay a percentage of the fees otherwise payable by it to...
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| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | 56(2) inapplicable to incorporated artist respecting producer paying mandatory contributions to the fund for the artist’s union | 144 |
7 October 2011 Roundtable, 2011-0412211C6 F - Feuillets T4A comptabilité d'exercice
A self-employed worker (a surveyor working on “lumpy” jobs), reports income on an accrual basis in his 2010 taxation year that is not actually...
8 October 2010 Roundtable, 2010-0373691C6 F - T4A et T5018 - Honoraires
CRA confirmed that, in contrast to T5018 slip paid to construction subcontractors, T4A slips do not include the GST/HST paid to the recipient for...
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| Tax Topics - Income Tax Regulations - Regulation 238 - Subsection 238(2) | unlike T4A, amounts paid include GST/HST | 306 |
26 June 2009 External T.I. 2009-0323711E5 F - Commissions à des travailleurs indépendants
CRA indicated that the requirement to file a T4A slip is the same whether a commission is paid to an individual (self-employed), a partnership or...
17 June 2008 Internal T.I. 2008-0276721I7 - Withholding requirements for non-resident employee
A Canadian-resident post-secondary educational institution (the "College") established a campus in a country with which Canada does not have a...
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| Tax Topics - Income Tax Regulations - Regulation 104 - Subsection 104(2) | Canadian college with non-Treaty country "business" campus | 196 |
29 May 2008 External T.I. 2007-0255321E5 F - Déclaration de renseignements
A health and social services centre is required to issue a T4A slip for various payments made to self-employed workers, including: reimbursement...
2 June 2008 External T.I. 2007-0262511E5 F - Obligation de produire un feuillet T4A
Regarding its policies as to the requirement to issue T4As for fees paid in excess of $500, CRA stated that it “will not insist on the issuance...
26 March 2008 External T.I. 2007-0224771E5 F - Sommes reçues en échange de références de clients
XYZco, which is in the residential construction business, makes a $500 referral payment to each former customer who provides the name of a...
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| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit | one-off referral fees to clients are likely non-taxable | 96 |
5 March 2008 External T.I. 2007-0256291E5 F - Bénévoles
After finding that volunteers working regular hours for a charity did not receive taxable benefits when the charity’s automobile made available...
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | volunteers working regular hours for a charity were not taxable when charity’s automobile made available to them to commute to work or receive a small allowance or meal or car expenses | 232 |
31 January 2008 External T.I. 2007-0230111E5 F - Déclaration des remboursements de dépenses
A payer is required to report on the T4A form different expense reimbursements paid to a person under a services contract, and amounts paid as GST...
30 October 2007 External T.I. 2007-0223871E5 - T4A Slip and Summary Form Reporting
Discussion of Requirements to Issue T4As for Services Rendered
19 November 2001 External T.I. 2001-0098455 F - Employés à l'étranger - production de T4
Employees of Canco are transferred to a related foreign corporation ("Foreignco") to render services to it and become non-residents. Canco...
26 August 1993, T.I. (Tax Window, No. 33, p. 2, ¶2637)
"Person" as used in Part II of the Regulations includes a non-resident person.
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Person | 15 |
Subsection 200(2)
Administrative Policy
15 March 2019 External T.I. 2018-0766021E5 - Obligation to prepare T4A slips
Pursuant to an agreement entered into between a (perhaps, foreign) Ministry and a Canadian university, funding was paid to the University for...
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| Tax Topics - General Concepts - Payment & Receipt | the payer is the person who has discretion and control over the funds | 122 |
S4-F14-C1 - Artists and Writers
Requirement to issue T4A even where amount exempt
1.74 Under subsection 200(2) of the Regulations, every payer of a research grant, scholarship,...
8 September 2015 External T.I. 2015-0584221E5 - T4A requirement- elementary scholarships
In confirming that a private school (the "School") is required to issue T4A Slips to report scholarships paid to, or on behalf of, its elementary...
S2-F1-C1 - Health and Welfare Trusts
1.55 For administrative simplicity, the taxable benefits provided by a health and welfare trust to employees should be reported by the trustee on...
23 July 1992 Memorandum 922191 (April 1993 Access Letter, p. 128, ¶C5-188)
Where both an employer and Agriculture Canada were paying a portion of a rent differential allowance to an employee, each would be considered an...
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 16 | |
| Tax Topics - Income Tax Regulations - Regulation 101 | 45 |
Paragraph 200(2)(g)
Administrative Policy
9 June 2005 Internal T.I. 2005-0115481I7 F - Avantages imposables/voyages
The Corporation sells products to incorporated or unincorporated retailers, awards them dollar-amount points based on their volumes of purchases,...
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | since the particular shareholder-employees who benefited from trips provided by their employer’s supplier were known, the supplier should issue T4As to them | 175 |
Subsection 200(3)
Administrative Policy
17 July 2019 External T.I. 2018-0777951E5 F - Avantage automobile
Mr. X, is employed by two related corporations, Corporation A and Corporation B. Corporation A, acquired a car that it makes available to Mr. X,...
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) | where 2 related employers, only a single benefit under the formula is calculated for each automobile | 115 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(k) | two related joint employers should agree on which of them will T4 an employee for the single s. 6(1)(e) or (k) benefit for the car provided by one of them to him | 107 |
2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.7, 2016-0674811C6 F - Allocations automobiles & dépenses afférentes
In the context of a general discussion of the course of action to be followed where an employer subsequently determines that T4 slips issued by it...
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| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h.1) | if vehicle allowance is too low, employee can include the allowance and deduct the vehicle expenses/T2200 production expected | 289 |