Authorization to Exercise Powers or Perform Duties of the Commissioner of National Revenue

Corporations Tax Act (Ontario)

Pursuant to subsection 98.1(6) ^a of the Corporations Tax Act,

1. I hereby authorize every person holding the position of Deputy Commissioner or Assistant Commissioner in the Canada Revenue Agency, or a person authorized to perform the duties of one of those positions, to exercise the powers and perform the duties of the Commissioner of Revenue under the Act and its regulations; and
2. I hereby authorize every officer holding a position in the Canada Revenue Agency listed in the attached Schedule, or a person authorized to perform the duties of that position, to exercise the powers and perform the duties of the Commissioner of Revenue under those provisions of the Act and its regulations that are set out in that Schedule.
3. This authorization is effective on the earlier of April 3, 2008 and the day that the regulation made under the Ontario Corporations Tax Act entitled "Provisions prescribed for the purposes of an agreement under section 98.1 of the Act" is filed.

Original signed by	Date
William V. Baker Commissioner of Revenue	April 3, 2008

SCHEDULE

Corporations Tax Act (Ontario)

Subsection 11(2) - May form an opinion that the value of inventory has been incorrectly determined by a corporation and may determine the value of that inventory

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit
Team Leader, Audit
Team Leader, Enforcement

Subsection 13(3) - May form a reasonable belief that a corporation has delayed the acquisition of an asset primarily for the purpose of claiming a deduction under section 13 or claiming a deduction at a higher specified rate and may deem the acquisition of that asset to have occurred on another date

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit
Team Leader, Audit
Team Leader, Enforcement

Subsection 17(3) - May fix the portions of the allowance for a coal mine to be deducted by a lessor and a lessee if they cannot agree

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit
Team Leader, Audit
Team Leader, Enforcement

Subsection 35(1) - May direct the maximum amount that may be deducted by a corporation as non-capital loss in certain situations

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit
Team Leader, Audit
Team Leader, Enforcement

Subsection 43.4(5) - May direct that certifications do not form part of the books and records of account of a corporation

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Assistant Director, Scientific Research and Experimental Development
Manager, Audit
Manager, Scientific Research and Experimental Development
Team Leader, Audit
Team Leader, Enforcement

Paragraph 43.9(10)(b) - May specify the information and documentation required in the application for an advance contract ruling

Headquarters Positions

Director General, Income Tax Rulings
Director, Income Tax Rulings
Manager, Income Tax Rulings

Paragraph 43.9(10)(c) - May give a ruling with respect to a contract under which an expenditure is made

Headquarters Positions

Director General, Income Tax Rulings
Director, Income Tax Rulings
Manager, Income Tax Rulings

Paragraph 43.9(12)(b) - May be satisfied that a ruling could not be applied for at an earlier time

Headquarters Positions

Director General, Income Tax Rulings
Director, Income Tax Rulings
Manager, Income Tax Rulings

Subsection 43.13(18) - May direct that an apprenticeship contract or training agreement does not form part of books and records

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit
Team Leader, Audit
Team Leader, Enforcement

Subsection 60.1(1) - May require a corporation to measure taxable paid up capital as of the day immediately before the commencement of a transaction, event or series of events

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit
Team Leader, Audit
Team Leader, Enforcement

Paragraph 62(1.3)(b) - May form an opinion that of the amount of an investment has not been replaced by new debt or equity or an increase in the related corporation's surplus

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit
Team Leader, Audit
Team Leader, Enforcement

Subsection 66.1(4.12) - May consider that an individual should have reasonably known that the statements made by the individual were falseField Positions

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Assistant Director, Scientific Research and Experimental Development
Manager, Audit
Manager, Scientific Research and Experimental Development
Team Leader, Audit
Team Leader, Enforcement

Subsection 66.1(4.13) - May be satisfied by evidence that an individual stating facts believed them to be true

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Assistant Director, Scientific Research and Experimental Development
Manager, Audit
Manager, Scientific Research and Experimental Development
Team Leader, Audit
Team Leader, Enforcement

Subsection 69(2.7) - May determine the amount of an associated group's net deduction that is reasonable in the circumstances

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit
Team Leader, Audit
Team Leader, Enforcement

Subsection 71(3) - May determine if the chief source of income of a corporation is neither farming nor a combination of farming and some other source of income

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit
Team Leader, Audit
Team Leader, Enforcement

Subsection 74.1(11) - May request that an allocation agreement be filed for a related group of life insurance companies and if such an agreement is not filed may determine the appropriate allocation

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit
Team Leader, Audit
Team Leader, Enforcement

Subsection 84(1.2) - May request a corporation which has filed an objection to provide required information

Headquarters Positions

Director General, Tax and Charities Appeals Directorate
Director, Tax and Charities Appeals Directorate
Manager, Tax and Charities Appeals Directorate

Field Positions

Chief of Appeals
Deputy Chief of Appeals
Appeals Manager
Team Leader, Appeals

Subsection 84(5) - Shall, on receipt of an objection, reconsider the assessment and vacate, confirm or vary the assessment or reassess and notify the corporation

Headquarters Positions

Director General, Tax and Charities Appeals Directorate
Director, Tax and Charities Appeals Directorate
Manager, Tax and Charities Appeals Directorate

Field Positions

Chief of Appeals
Deputy Chief of Appeals
Appeals Manager
Team Leader, Appeals

Subsection 87(5) - May vacate or vary an assessment and assess or reassess to give effect to the terms of a settlement

Headquarters Positions

Director General, Tax and Charities Appeals Directorate
Director, Tax and Charities Appeals Directorate
Manager, Tax and Charities Appeals Directorate

Field Positions

Chief of Appeals
Deputy Chief of Appeals
Appeals Manager
Manager, Litigation
Team Leader, Litigation

Section 91 - On application, may extend the time to serve a notice of objection or to institute an appeal

Headquarters Positions

Director General, Tax and Charities Appeals Directorate
Director, Tax and Charities Appeals Directorate
Manager, Tax and Charities Appeals Directorate

Field Positions

Chief of Appeals
Deputy Chief of Appeals
Appeals Manager
Manager, Litigation
Team Leader, Appeals
Team Leader, Litigation

Subsection 93(1) - May authorize a person for any purpose related to the administration and enforcement of the Act

Headquarters Positions

Deputy Assistant Commissioner, Compliance Programs Branch
Director General, Enforcement and Disclosures Directorate
Director General, International and Large Business Directorate
Director General, Small and Medium Enterprises Directorate
Director, Enforcement and Disclosures Directorate
Director, International and Large Business Directorate
Director, Small and Medium Enterprises Directorate

Field Positions

Director, Tax Services Office

Subsections 93(2), (3) and (4) - May require a person to produce specified information or documents

Headquarters Positions

Deputy Assistant Commissioner, Compliance Programs Branch
Director General, Enforcement and Disclosures Directorate
Director General, International and Large Business Directorate
Director General, Small and Medium Enterprises Directorate
Director, Enforcement and Disclosures Directorate
Director, International and Large Business Directorate
Director, Small and Medium Enterprises Directorate

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Assistant Director, Scientific Research and Experimental Development
Manager, Audit
Manager, Scientific Research and Experimental Development

Subsection 93(6) - May certify a copy of a document

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Assistant Director, Scientific Research and Experimental Development
Manager, Audit
Manager, Scientific Research and Experimental Development
Team Leader, Audit
Team Leader, Enforcement
Investigator, Enforcement
Auditor, Enforcement

Subsection 94(1) - May designate another place where records and books may be kept

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Assistant Director, Scientific Research and Experimental Development
Manager, Audit
Manager, Scientific Research and Experimental Development
Team Leader, Audit
Team Leader, Enforcement

Subsection 94(2) - May specify and require the books and records to be kept by a corporation

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Assistant Director, Scientific Research and Experimental Development
Manager, Audit
Manager, Scientific Research and Experimental Development
Team Leader, Audit
Team Leader, Enforcement

Section 109 - May deem an amount to be proper and accept that amount

Headquarters Positions

Director General, Tax and Charities Appeals Directorate
Director, Tax and Charities Appeals Directorate
Manager, Tax and Charities Appeals Directorate

Field Positions

Chief of Appeals
Deputy Chief of Appeals
Appeals Manager
Manager, Litigation
Team Leader, Appeals
Team Leader, Litigation

Subsection 109.1(1) - May remit all or part of the interest and penalties payable by a corporation and make any assessment or reassessment of interest and penalties payable by the corporation on account of the remission

Headquarters Positions

Deputy Assistant Commissioner, Compliance Programs Branch
Director General, Enforcement and Disclosures Directorate
Director General, International and Large Business Directorate
Director General, Small and Medium Enterprises Directorate
Director, Enforcement and Disclosures Directorate
Director, International and Large Business Directorate
Director, Small and Medium Enterprises Directorate

Field Positions

Director, Tax Services Office
Chief of Appeals
Assistant Director, Audit
Assistant Director, Enforcement
Deputy Chief of Appeals
Appeals Manager
Manager, Audit
Manager, Litigation
Team Leader, Appeals
Team Leader, Audit
Team Leader, Enforcement

CORPORATIONS TAX ACT REGULATIONS

NOTE:

• These Regulations have been made in English only by the province of Ontario.

Paragraph 2 of subsection 203(7) of Regulation 183 - May notify a taxpayer that an agreement must be filed and if it is not filed may allocate an amount to each taxpayer

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit
Team Leader, Audit
Team Leader, Enforcement

Subsection 204(15) of Regulation 183 - May accept a late election to classify certain qualifying property

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit
Team Leader, Audit
Team Leader, Enforcement

Paragraph 302.1(3)(b) of Regulation 183 - May form an opinion that an undue reduction in the total amount of tax payable was not a purpose or intended ancillary result of an agreement or an arrangement

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit

Subsection 302.1(5) of Regulation 183 - On joint request, may determine an amount that is reasonable and permit an employer to deduct that amount and may approve the form of the request

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit

Paragraph 2 of 302.1(7) of Regulation 183 - May form an opinion that an arrangement or an agreement can reasonably be linked to an agreement or an arrangement described in paragraph 1

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit
Team Leader, Audit
Team Leader, Enforcement

Section 312 of Regulation 183 - May agree to determine the amount of taxable income in a province

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Assistant Director, Scientific Research and Experimental Development
Manager, Audit
Manager, Scientific Research and Experimental Development
Team Leader, Audit
Team Leader, Enforcement

Paragraph 2 of subsection 1101(6) of Regulation 183 - May request that an allocation agreement be filed for a related group of corporations or, in the absence of such an agreement, determine the appropriate allocation

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Assistant Director, Scientific Research and Experimental Development
Manager, Audit
Manager, Scientific Research and Experimental Development

Subsection 1101(15) of Regulation 183 - Shall designate a non-profit organization or hospital research institute as an eligible research institute where specified conditions are met

Headquarters Positions

Director General, Income Tax Rulings
Director, Income Tax Rulings
Manager, Income Tax Rulings

Subsection 1101(16) of Regulation 183 - May authorize an alternate effective date of a designation

Headquarters Positions

Director General, Income Tax Rulings
Director, Income Tax Rulings
Manager, Income Tax Rulings

Subsection 1101(17) of Regulation 183 - May revoke a designation

Headquarters Positions

Director General, Income Tax Rulings
Director, Income Tax Rulings
Manager, Income Tax Rulings

Subsection 1101(19) of Regulation 183 - May authorize an alternate effective date of a revocation

Headquarters Positions

Director General, Income Tax Rulings
Director, Income Tax Rulings
Manager, Income Tax Rulings

Subsection 13(1) of Regulation 318/97 - May direct that a certification does not form part of the records and books of a financial institution

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement
Manager, Audit
Team Leader, Audit
Team Leader, Enforcement

Subsection 13(2) of Regulation 318/97 - May direct a fund to cease certifying investments and order all or certain investments to be deemed as not eligible investments

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement

Subsection 13(3) of Regulation 318/97 - May be satisfied that a fund will comply with the Minister's directions and may revoke the direction and order given under subsection 13(2) and may approve the extent to which investments may be considered to be eligible investments

Field Positions

Director, Tax Services Office
Assistant Director, Audit
Assistant Director, Enforcement

^a R.S.O. 2006, c. 9, Schedule D, s. 4.

Date modified:

2015-04-02