Canada Revenue Agency

News & Analysis as of

CRA3 – Final Draft Regulatory Technical Standards in relation to Disclosure Requirements for Structured Finance Instruments

On 24 June 2014, ESMA published its Final Report on the draft regulatory technical standards under CRA3. With respect to structured finance instruments, the Final Report sets out draft standards for the information to be...more

EBA Publish Final Draft RTS on Equity Exposures

On August 5, EBA published its final draft regulatory technical standards (RTS) specifying the treatment of equity exposures according to Article 495(3) of Regulation No 575/2013 Capital Requirements Regulation (CRR). ...more

CRA3: ESMA publishes final draft Regulatory Technical Standards on disclosure requirements for Structured Finance Instruments

Executive Summary - Following the consultation paper published by the European Securities and Markets Authority (ESMA) in February 2014, on 24 June 2014 ESMA published its final draft of the Regulatory Technical...more

CRA Required to Reassess in Accordance with Terms of Settlement

The recent decision in Bolton Steel Tube Co. Ltd. v. The Queen, 2014 TCC 94, confirms that the CRA is required to reassess a taxpayer in accordance with terms of settlement. In its decision, the Tax Court provides useful...more

Redeveloping Redevelopment: Recent Legislation

THE RISE AND (UNINTENDED) FALL OF REDEVELOPMENT IN CALIFORNIA. The rise and fall of redevelopment agencies in California has been extensively written about, including in this publication. The history of redevelopment...more

Key Takeaways from American Bankers Association 2014 Regulatory & Compliance Conference

For those who did not get to attend in June, this year’s American Bankers Association Regulatory & Compliance Conference brought together a couple of thousand attendees to hear from regulators, presenters and ABA staff and...more

CRA: Tax treatment of Ponzi scheme investments

We have previously written about court decisions on the tax results arising from taxpayers’ (failed) investments in Ponzi schemes (see our posts on Roszko v. The Queen (2014 TCC 59), Johnson v. The Queen (2011 TCC 54) and...more

Revised CRA Policy Heralds Focus on Contemporaneous Transfer Pricing Documentation

CRA released an updated transfer pricing memorandum, TPM-05R, Requests for Contemporaneous Documentation, in March, which describes the procedural aspects of transfer pricing documentation requirements in substantially more...more

Bolton Steel Tube: TCC Orders Crown to Reassessment in Accordance with Settlement

In Bolton Steel Tube Co. Ltd. v. The Queen (2014 TCC 94), the Tax Court of Canada allowed the taxpayer’s motion requesting an Order that would require the CRA to reassess the taxpayer in accordance with the terms of a...more

STEP Canada: CRA Provides Update on Audit Activities

The Society of Trust and Estate Practitioners (STEP Canada) held its 16th annual national conference on June 16-17 in Toronto. As it has in previous years, the conference featured a Canada Revenue Agency Roundtable wherein...more

Spruce Credit: Avoidance transactions and the Duke of Westminster

In Spruce Credit Union v. The Queen (2014 FCA 143) the Federal Court of Appeal upheld the lower court’s interpretation and application of the inter-corporate dividend deduction under subsection 112(1) of the Income Tax Act...more

OCC Integrates Interagency Rules, Proposes Integrated Licensing Rules

On May 16, the OCC issued a final rule to integrate its interagency rules, which would combine, without any substantive amendments, rules related to consumer protection in insurance sales, BSA compliance, management...more

CFPB Report Highlights Nonbank Supervisory Findings

On May 22, the CFPB published its Spring 2014 Supervisory Highlights report, its fourth such report to date. In addition to reviewing recent guidance, rulemakings, and public enforcement actions, the report states that the...more

CFPB highlights unlawful practices by consumer reporting agencies, debt collectors and payday lenders

In its Spring 2014 Supervisory Highlights report issued yesterday, the CFPB highlighted deficiencies and violations it found during examinations of consumer reporting agencies (CRAs), debt collectors and payday lenders. The...more

Leroux: CRA Owes Duty Of Care To Taxpayer

Can a Canadian taxpayer successfully sue the Canada Revenue Agency? - In recent years, taxpayers have brought a number of civil actions against the Canada Revenue Agency (the “CRA”). The allegations in such cases...more

FDIC Releases Resource Guide to Help Institutions Evaluate Opportunities with Community Development Financial Institutions

The Federal Deposit Insurance Corporation (FDIC) has produced a resource guide, Strategies for Community Banks to Develop Partnerships with Community Development Financial Institutions, to inform institutions of strategies to...more

Orrick's Financial Industry Week In Review

Council of the EU Adopts Bank Recovery and Resolution Directive - On May 6, the Council of the EU adopted at first reading the text of the Bank Recovery and Resolution Directive (BRRD). The BRRD seeks to harmonize...more

Banking Agencies Issue Revised CRA Exam Procedures

On April 18, the OCC, FDIC, and Federal Reserve Board released revised Community Reinvestment Act (CRA) examination procedures applicable to institutions with total assets greater than $1.202 billion as of December 31 of...more

More Guidance From The CRA On Bitcoin Activities And Transactions

Following the recent IRS publication on the U.S. tax treatment of bitcoin activities and transactions, the CRA has issued further guidance on the Canadian tax issues arising in respect of the virtual currency....more

Eastern Pompano Beach Is Open For Business

Eastern Pompano Beach has quickly positioned itself to become the next hot spot for development in South Florida. Investors are betting that recent public sector efforts will translate into a thriving community....more

CRA Provides Update On NPO Project

In 2009, the CRA commenced a broad review of the non-profit organization sector. You or your clients may have received a CRA questionnaire asking that the NPO provide information or documents in respect of its structure,...more

International And Transfer Pricing Audits: Toronto Centre Canada Revenue Agency & Professionals Breakfast Seminar

At the Toronto Centre Canada Revenue Agency & Professionals Breakfast Seminar on February 18, 2014, the CRA provided an update on international and transfer pricing audits. The slides can be found here. The discussion was led...more

Mississippi Regulatory Compliance Group Quarterly Report Vol. 25 No.1

In This Report: - Resurgence of Redlining Scrutiny - Diversity, a New Requirement - Revisiting Red Flags - Know Before Your Owe - Questions About ATR and QM - MRCG Meeting – February 20,...more

House Democrats Encourage FTC Scrutiny Of Consumer Reporting Agencies’ Add-On Products Marketing

On December 18, a group of House Democrats sent a letter urging the FTC to focus on the online marketing of products and services by consumer reporting agencies (CRAs). The lawmakers assert that CRAs “often require consumers...more

Editorial: Who’s The Fairest Lender Of Them All? As Government Scrutiny Intensifies, Don’t Get Snowed Under By Fair-Lending Laws

In the past few years, the federal government has devoted substantial resources to scrutinizing and litigating what it perceives to be unfair, deceptive or abusive mortgage-lending practices. Looking forward, all indications...more

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