On December 5–6, 2017, a delegation of Canadian Income Tax Committee and Canadian Commodity Tax Committee members assembled in Ottawa, Ontario, for TEI’s annual liaison meetings with representatives of the Canada Revenue Agency and Department of Finance. This year’s meetings featured robust agendas covering a range of tax law, policy, and administration issues of importance to many TEI members.
This year’s income tax agendas addressed, among other things, withholding tax on the donation of shares acquired through stock option exercise; improvements to the 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 on foreign mergers; waiver of the requirement to file NR4 returns for exempt payments; certification of qualifying non-resident employers under the R102 Program; statute of limitations for assessment of Part XIII tax liability; 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 resources 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 institutions annual information returns; qualifying environmental trusts; amended returns; agency relationships and elections; credit adjustments; section 156 elections; production taxes; place of supply rules; the pre-payment of assessments; tax account set offs; 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 TEI’s International President, Robert L. Howren, Vice President for Canadian Affairs, Fraser E. Reid, Executive Director, Eli J. Dicker, and Tax Counsels, Watson M. McLeish and Pilar Mata.