TEI Holds Liaison Meetings With Canada Revenue Agency and Department of Finance

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On December 5 and 6, a delegation including members of TEI’s Canadian income tax and Canadian commodity tax committees assembled in Ottawa for TEI’s annual liaison meetings with representatives of the Canada Revenue Agency and the Department of Finance. This year’s meetings featured robust agendas covering a range of tax law, policy, and administrative issues of importance to many TEI members.

This year’s income tax agendas addressed, among other topics, withholding tax on the donation of shares acquired through the exercise of stock options; improvements to the Canada Revenue Agency’s My Business Account online portal; Regulation 105 waivers; the income tax objection process for large corporations; Section 116 procedures for tax-deferred dispositions of taxable Canadian property in foreign mergers; waiving the requirement to file NR4 returns for exempt payments; certification of qualifying nonresident employers under the R102 program; the statute of limitations for assessing tax liability under Part XIII of the Canada Business Corporations Act; short-form versus long-form amalgamations in the bump context; and interest rates on tax debts and tax refunds.

This year’s commodity tax agenda addressed issues related to sales of oil and gas resource properties; assessments prior to the resolution of auditor-requested rulings; drop shipments; emissions allowances; the new entity verification process; pension plan rebates; waivers; maintenance of and access to company information; large case file registrants; My Business Account training and outreach; joint venture elections; CRA’s upcoming out-of-pocket cost publication; financial institution annual information returns; qualifying environmental trusts; amended returns; agency relationships and elections; credit adjustments; Section 156 elections; production taxes; place of supply rules; prepayment of assessments; tax account setoffs; and potential changes to the rules related to partnerships.

Paul T. Magrath, chair of the Canadian income tax committee, led TEI’s income tax delegation, and David Card, chair of the Canadian commodity tax committee, led the commodity tax delegation. The delegations were accompanied by Robert L. Howren, TEI’s international president; Fraser E. Reid, vice president for Canadian affairs; Eli J. Dicker, executive director; and Watson M. McLeish and Pilar Mata, tax counsels. The links to the liaison meeting questions are available on TEI’s website.

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