Canadian Revenue Agency

News & Analysis as of

One Number to Rule Them All: The New Common Business Number Act

On April 30, 2015, Bill 12: the Common Business Number Act (the “Act”) came into force in Alberta. The Act created the authority for Alberta to adopt the Canada Revenue Agency’s (“CRA”) Business Number system (“BN”). The BN...more

BP Canada: CRA Entitled to Tax Accrual Working Papers

In BP Canada Energy Company v. Minister of National Revenue (2015 FC 714), the Minister brought an application pursuant to subsection 231.7(1) of the Income Tax Act (Canada) (the “Act”) before the Federal Court of...more

The Magic GST/HST Registration (or How to Make a Multimillion-Dollar GST/HST Assessment Disappear)

It is well known that a GST/HST-registered person can purchase certain types of commercial real property without paying GST/HST to the vendor. ...more

Crowdfunding: Update From the CRA

In a short technical interpretation (CRA Document 2015-0579031I7 “Crowdfunding” (April 1, 2015)), the CRA has restated its views on the tax treatment of amounts raised via crowdfunding arrangements. The CRA stated that...more

Loss Determinations: No Time Like the Present

Under subsection 152(1.1) of the Income Tax Act, a taxpayer may apply for a determination of losses for a tax year. A taxpayer typically requests a loss determination after the CRA has issued a nil assessment. ...more

CRA Appoints New Ombudsman

The CRA has appointed a new Taxpayers’ Ombudsman, the second since the position was created in 2008. From the CRA news release: April 10, 2015 – Ottawa – Canada Revenue Agency - The Honourable Kerry-Lynne...more

Highlights from the Toronto Centre CRA & Professionals Group Breakfast Seminar – February 19, 2015

On February 19, 2015, at the Toronto Centre CRA & Professionals Group Breakfast Seminar CRA representatives provided an update on two topics: 1) online CRA e-services, and 2) Regulation 102 and Regulation 105 waivers for...more

Highlights from the Toronto Centre CRA & Tax Professionals Groups Breakfast Seminar (November 6, 2014)

On November 6, 2014 at the Toronto Centre Canada Revenue Agency & Tax Professionals Breakfast Seminar, representatives from the CRA provided an update on the Income Tax Rulings Directorate (“Rulings”) and discussed current...more

CRA’s New Pre-Rulings Consultations Service

On November 26th, 2013, the Canada Revenue Agency (“CRA”) participated in a Roundtable session at the 65th Annual Tax Conference of the Canadian Tax Foundation held in Toronto, Ontario. The panelists announced a one-year...more

The Canada Revenue Agency’s Voluntary Disclosure Program: Current Processing Issues

The Canada Revenue Agency’s Voluntary Disclosure Program (VDP) has gone through a number of organizational changes over the past few years....more

Sales Of Condominium Units Under Audit By Canada Revenue Agency

A Canada Revenue Agency (“CRA”) audit initiative is targeting taxpayers who have recently sold condominium units they did not occupy or occupied for only a short period of time (the “CRA Condo Project”)....more

Provincial Income Allocation: Salaries And Wages To Include All Taxable Benefits

In the Provincial Income Allocation Newsletter No. 4 (March 2013), the Canada Revenue Agency notes that the Allocation Review Committee (“ARC”) has changed its position on amounts previously excluded in calculating “salary...more

Tax Executives Institute Raises Important Audit Process Questions And Concerns In Its Annual Meeting With The Canada Revenue...

Earlier this month, the Tax Executives Institute, Inc. (TEI) raised a number of important income tax administration issues in its annual meeting with the Canada Revenue Agency. Concerns were expressed about how the CRA...more

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