Karen Wilkinson at Deloitte was kind enough to point out to me that the CRA has reversed itself on whether a 116 certificate is necessary when Canadian corporations with non-resident shareholders amalgamate. IT-474R2, issued on December 17, 2007, contained the…
IT-474R3
The CRA recently released Interpretation Bulletin IT-474R3 (“Amalgamations of Canadian Corporations”). One of the big changes relates to the requirement to obtain a certificate under section 116 of the Income Tax Act. Previously, the CRA took the position that a…
Charity suspended
The Tax Court has rejected an application by International Charity Association Network under subsection 188.2(4) of the Income Tax Act (Canada) for a postponement of a suspension “of its authority to issue an official tax receipt for one year beginning…
Corporate information reporting
The Ministry of Government Services has issued a notice to clients that discusses the effect of the single administration of Ontario corporate income taxes (which will be implemented by January 1, 2009) on the process for filing annual corporate returns…
Merry Christmas
Merry Christmas everyone, from your friends at the Department of Finance: Government of Canada Announces Technical Amendments to Clarify the Specified Investment Flow-Through Entity Tax Rules.
Interest relief
The late 1980’s and early 1990’s were riotous times for tax shelters and their promoters. Unfortunately, many of them tended to leave taxpayers with severe hangovers in the form of large tax bills complete with assessments for interest amounts that tripled or quadrupled the amount of tax payable. What to do about that interest?
Bill C-28
Bill C-28—”an Act to implement certain provisions of the budget tabled in Parliament on March 19, 2007 and to implement certain provisions of the economic statement tabled in Parliament on October 30, 2007″—received Royal Assent on Friday. The bill became…
Third parties
One of my very first posts on this blog dealt with demands for information about third parties. The saga continues in Canada (National Revenue) v. The Greater Montréal Real Estate Board, 2006 FC 1069, in which the Court vacated its own ex parte order requiring the Board to turn over the information requested by the CRA. The Court founds as follows:
10 Years
In a post I wrote some time ago, I argued that the 10-year limitation rule for fairness (taxpayer relief) applications is ambiguous. I also noted that the CRA believes the rule is clear, and apparently it maintains that position still,…
CRA Report
The CRA has made its annual report to Parliament, and parts of it make for interesting reading. Essentially the report amounts to the CRA’s report card on itself. The report discusses outstanding tax debts among other things. The report notes…