The CRA runs a volunteer tax preparer program, which is a Smart Idea. Beginning in 2016, the CRA will require all volunteer preparers to get police checks, which is a Dumb Idea.
Consent steeplechase
Craig Burley reports on the latest from the CRA about authorizations. Apparently Tax Centres are no longer processing faxed authorization forms. Update December 19, 2014. I spoke to an Appeals officer today who said that I couldn’t fax an authorization…
97(2) Abuse
The CRA says that forming a partnership consisting only of Canadian partners to take advantage of the 97(2) rollover and then immediately afterward adding a non-resident partner is abusive. It would attempt to apply the GAAR. (CTF Roundtable Q6).
Restrictive covenant relief
Earlier this year, the CRA said that nominal consideration for a non-compete would be proceeds of disposition so that 56.4(7) would not apply to the covenant. Apparently, the CRA reversed this position at the CTF Roundtable yesterday: $1 (but no…
New folio on amalgamations
The CRA has published a new folio on amalgamations here.
Future income tax assets
The CRA takes the position that a future income tax asset it not an asset for the purposes of the QSBCS and SBC definitions. Such an asset should be ignored when determining whether a share is a QSBCS or a…
98(3) News
Neal Armstrong is on a sarcasm roll this week. After noting that the CRA, in a recent interpretation (2014-0540611E5E), took the position that a 98(3) election is valid only if it is made for all property of the partnership and…
Tax preparer punishment
Here’s some good news for a change: “Tax preparer given an 18-month conditional sentence and a $377,024 fine for filing false tax returns.” I’ve seen too many cases where unscrupulous preparers file false returns for clueless taxpayers who are left…
Access to information requests
I’ll sometimes make a Privacy Act or access to information request so that I can see the auditor’s or appeals officer’s file (or both). The CRA has published a webpage on how to make such requests, which is a welcome…
Paper-less
Neal Armstrong at taxinterpretations.com reported yesterday on CRA TI 2014-0526121E5, which confirmed that electronic copies of original records should suffice for the purposes of complying with the provisions of the Income Tax Act relating to business records. Keeping originals might…