CRA Interpretations

List Of CRA Interpretations

Donation of Flow-Through Shares

Donation of Flow-Through Shares – subparagraph 38(a.1)(i), subsection 248(35) through (41) and section 237.1 Because of the flow-through nature of the deductions available to a subscriber of a flow-through share, the deemed cost of such shares to the subscriber is nil. With the elimination of capital gains taxes on shares of a public corporation donated to

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Eligible Dividend Designation

Eligible Dividend Designation – Subsection 89(14) A taxable dividend, including a deemed dividend received by a resident of Canada after 2005, is an eligible dividend only if the corporation designates it as an eligible dividend. To designate a taxable dividend as an eligible dividend, the corporation must notify in writing the person to whom it pays

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Example of instalment interest and penalty calculation

Example This is an example of how we calculate instalment interest and penalty using the offset method. Corporation D has a December 31 year end and has to make monthly instalment payments of $75,000 starting in January 2019. Corporation D only makes two instalment payments in the year. It makes one payment of $120,000 on

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Functional Currency Tax Reporting Rules

Functional Currency Tax Reporting Rules Question 1 What is the meaning of “debt obligation” as the term is used in new section 261 of the Act? Does it include trade payables as well as inter-company loans and advances? If so, where a taxpayer has both a payable and receivable to and from the same entity,

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GI-066 How a Charity Completes Its GST/HST Return

How a Charity Completes Its GST/HST Return GST/HST Info Sheet GI-066 February 2019 This version updates and replaces the one dated May 2015. It incorporates revisions under the heading “Step 2 – Determine the total ITCs and adjustments” to clarify the information presented, and to reflect the repeal of the GST/HST rebate for the accommodation portion of

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How to complete Form R105, Regulation 105 Waiver Application

Section I – Applicant identification 1. Indicate any business number or similar identifier that the CRA may have issued to the applicant. For example, the applicant may have received a temporary tax number (TTN) or an individual tax number (ITN) if they filed a Canadian income tax return or received a waiver. If the applicant

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IC00-1R5- Voluntary Disclosures Program

Application 1. This information circular cancels and replaces Information Circular IC00-1R4, Voluntary Disclosures Program, dated March 21, 2014. 2. In this information circular, the term “taxpayer” includes an individual, an employer, a corporation, a partnership, a trust, a Goods and Services Tax/Harmonized Sales Tax (GST/HST) registrant/claimant or a registered exporter of softwood lumber products. 3. Unless otherwise

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IC00-1R6 – Voluntary Disclosures Program

Application 1. The Voluntary Disclosures Program (VDP) applies to disclosures relating to income tax, source deductions, excise duties under the Excise Act, 2001, excise tax and GST/HST under the Excise Tax Act, as well as charges under the Air Travellers Security Charge Act and Softwood Lumber Products Export Charge Act, 2006. This information circular provides

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IC01-1 Third-Party Civil Penalties

Foreword This information circular provides a framework for the application of third-party civil penalty provisions in section 163.2 of theIncome Tax Act and section 285.1 of the Excise Tax Act. The third-party civil penalty provisions evolved from a need to deter tax shelter or tax shelter-like promotions with inflated asset values and faulty assumptions. When the third-party civil penalty

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IC06-1 Income Tax Transfer Pricing and Customs Valuation

Introduction 1. The purpose of this information circular is to address taxpayers’ question “Why can’t the same transfer price used for income tax purposes be used for customs purposes?” 2. This document outlines the similarities and differences between valuation for customs purposes (customs valuation) and transfer prices for income tax purposes (income tax transfer pricing),

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IC07-1R1 Taxpayer Relief Provisions

Application 1. This information circular cancels and replaces Information Circular IC07-1, Taxpayer Relief Provisions, dated May 31, 2007. 2. In this information circular, the term taxpayer includes an individual, an employer or a payer, a corporation, a partnership, a trust, an estate, and an organization. All of these entities can ask for relief from the minister of

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IC12-1 GST/HST Compliance Refund Holds

Application 1. In this information circular, the following terms apply: Insolvency practitioner refers to a trustee in bankruptcy, a receiver, or a liquidator, and every agent or other person administering, managing, winding up, controlling, or otherwise dealing with the property, business, estate, or income of a corporation, other than a shareholder, director, officer or employee of the

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IC13-1R1 Pooled Registered Pension Plans (PRPP)

Pooled Registered Pension Plans (PRPP) This circular cancels and replaces IC13-1 dated February 18, 2013. ¶ 1. This circular explains the provisions of the Income Tax Act (ITA) and the Canada Revenue Agency (CRA) requirements for the registration of a pooled pension plan. Authority ¶ 2. Section 147.5 of the ITA contains the registration requirements for pooled pension plans, as well as the rules

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IC13-2R1 Government programs collection policies

Introduction This information circular gives you a general overview of the government programs collection policies that the Canada Revenue Agency (CRA) has for individuals, businesses, and organizations that owe money other than taxes to the Crown. It will help you understand your rights and responsibilities when you deal with the CRA. The CRA uses the term “government programs”

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IC13-3 Customs collections policies

Introduction This information circular gives you a general overview of the Customs collections policies of the Canada Revenue Agency (CRA) for individuals, businesses, and organizations that owe money to the Crown relative to goods imported into Canada. It will help you understand your rights and responsibilities when you deal with us. In this circular, we

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IC18-1 Tax-Free Savings Accounts

Tax-Free Savings Accounts ¶ 1. This circular explains certain provisions of the Income Tax Act (ITA) that apply to tax-free savings accounts (TFSAs) and outlines the registration requirements of the Canada Revenue Agency (CRA) for issuers of TFSAs. Additional information is available in the publications listed in Part V below. Authority ¶ 2. Section 146.2 of

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