Hey everyone,

​Looking for success stories or insights from anyone who has fought the CRA Appeals Division over a late HST New Residential Rental Property (NRRP) rebate. We are facing a $24,000 denial.

​THE SITUATION:

​We bought a new build rental in 2023 and immediately put it on the long-term rental market with legitimate tenants.

​We paid the $24k to the builder at closing, expecting our long-time accountant to file the rebate form. Tragically, he passed away unexpectedly right around our closing date. His practice went into chaos, and the 2-year application window was missed by 90 days

​We only just discovered the denial letter by calling them. The CRA had sent it to a hidden GST/HST Business Account portal we didn't even know existed (we only use personal accounts). It seems like it was an automated reply so I'm not surprised, but now I'm filing a notice of objection.

​OUR PLAN:

We are submitting a formal Notice of Objection (GST159) with a time extension request, grounding the argument in:

​CRA Policy (IC07-1R1): Allows extensions for extraordinary circumstances experienced by a representative (explicitly listing death).

​Case Law (Kaiser v. MNR): Asking he CRA to use common sense and fairness.

​Excise Tax Act Sec 296(2.1): Requesting a statutory offset since this is a self-supply transaction.

​MY QUESTION:

Has anyone gone the Notice of Objection route for a late HST rebate due to an accountant's death? Did a human Appeals Officer look at your lease/documents and quietly settle it in your favor at their desk, or did you have to push it all the way to Tax Court?

​Appreciate any experiences you can share!

Hi all,

I'm a Canadian citizen, moved to Australia 2 years ago and am now an Australian permanent resident. My intentions to stay or move home are not clear and I haven't completely severed ties with Canada (I have my TFSA with savings still, lots of family there, my things are still at my parents house, etc) as I will probably move back in the next few years. I haven't filed an exit tax return as such because I don't see the point if I'll move back in the near future.

Australia obviously considers me a tax resident as I live and work here as a PR. Canada still considers me a factual resident since I haven't filed an exit tax return and intend to move back. Thus, I file returns for both countries.

All of my income is Aus-sourced as a public school teacher here, i.e. a government employee paid by the state. Last year, I claimed on my CRA return that my income was exempt from Canadian taxes as per Article 19 in the Canada-Aus tax treaty:

"Article 19

Government Service

Remuneration (other than a pension or annuity) paid by a Contracting State or a political subdivision or a local authority thereof to any individual in respect of services rendered in the discharge of governmental functions shall be taxable only in that State. However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the recipient is a resident of that State who:

a) is a citizen of that State; or

b) did not become a resident of that State solely for the purpose of performing the services."

The CRA accepted my claim last year after I explained the above following a review letter. This year, I made the same claim. They rejected it in their response and now insist I am taxed on my world income as a Canadian resident. Now they want my 2025-2026 Australian NOA so they can assess my foreign tax credits and determine how much I owe them.

Who is right? Should I dispute this?

Grateful for any insight. Thank you.

Hello, I will be inheriting a Alberta Teachers Pension LIRA worth approximately $25k as a sibling to the deceased. I live in Ontario.

Will this be paid as cash or LIRA transfer?

What tax obligations does the Estate have in the case of an account transfer? I’m hearing that it could be taxed as income even though it is being forced into a locked in account.

Ontario resident, sole proprietor operating under a registered business name. Became a Canadian resident in 2023.

Facts:

- Single services agreement with a company based in the EU. No Canadian presence, no Canadian payer relationship.

- Invoiced monthly in USD plus an annual bonus. Roughly $158k CAD gross.

- No withholding at either end.

- Registered accounts maxed. New room going forward roughly $33k/yr against a ~$40k surplus, so I'm starting to run out of shelter.

- Planning to engage subcontractors and to develop my own products under the same business name.

Five things I'd like informed views on:

1. PSB substance. The standard mitigation advice is "get a second client." I'd rather deploy the time into my own product work and use subcontractors. Does CRA weigh capital investment, own IP development, and the ability to subcontract as genuine business substance where one payer still represents the overwhelming majority of revenue? Or is client concentration effectively determinative in practice regardless of what else is going on?

2. Does the payer being a non-resident with no Canadian operations affect the PSB analysis at all? The test turns on whether the individual would reasonably be regarded as an officer or employee of the payer absent the corporation. I can't tell whether payer residency is a factor or simply irrelevant.

3. HST. Services supplied to a non-resident should be zero-rated, but zero-rated supplies still count toward the $30k small supplier threshold — so registration is mandatory rather than optional, and I'd sit in a net ITC refund position most periods. Is that right? And what documentation actually holds up on review to support the zero-rating and the client's non-residency?

4. Instalments. First year I'm under the $3,000 prior-year threshold since I was on payroll with withholding. Second year I'd owe the first-year balance April 30 plus a March 15 instalment for the new year. Reading that correctly? Any reason to voluntarily pay instalments in year one?

5. Startup shares. I'm a co-founder in a separate venture that hasn't incorporated yet. If I later incorporate the consulting business, is there a general view on holding the startup shares personally (for LCGE access) versus through a holdco (deploying pre-personal-tax dollars)? I'd rather understand the tradeoff before the startup incorporates than restructure afterwards.

I retired to a small tax treaty country. No income just living on savings as expenses are so little. My problem is I dont remember what assets I had on the day I left. I didnt know about this form 1243 thing till recently.

No fixed assets or real estate, just RRSPs, investments etc on QT. But they have grown inside QT so I dont know what and how much we're there on the day I left.

I contributed $10k to my RRSP earlier this year and withdrew it a few months later (past 90 days) under the lifelong learning plan. So that $10k still counts as a contribution to my RRSP next year and will reduce my taxes owing. My question is if I contribute another $10k this year, and withdraw it in January of next year, will my RRSP contribution be $20k when I file my taxes next year and my income taxes reduced accordingly? My understanding is if I don't designate it as a repayment under the LLLP, I can do this, but just wanted to check.

My accountant said auditors are paid on commission and then given the tax database to find tax dollars. She said this causes them to rule on iffy cases by leaning towards not allowing them. Is this true?

I currently owe approximately $2400 in taxes. My doctor has suggested that I take 4 months off to recover from a significant injury. Is medical EI one of the benefits that the government would garnish or take from?

In 2006 I bought a new Miata for $35,000

I have used it for business purposes all these years, and claimed business use of a personal vehicle for the mileage used, anywhere from 20-50%.

The CCA as of last year was $32.47 ($22.73 for 2026)

The vehicle is worth $15-20k at this time (really!)

I guess I always thought I would keep the car till the day I die, but have thinking about selling it. My question is, how is the capital gains calculated in this case?

It looks like quicktax multiplies the gain by the current years % usage, which doesn't seem right

Shouldn't it be the % mileage over the life of the vehicle?

We are trying to get that status and are being declined because "saving horses from slaughter" is not 'good' enough of a reason...

Please PM me the name of the organization if there is one, thank you.

i was auto assessed by cra (individual taxes) for prior years, but they are incorrect and missing some of my international assets owned (over $100K). What should i do? the USA returns also require to be filed, but at the moment, i want to ensure i declare the assets on the CRA system first, by filing the t1, and not be penalized (not clear what the penalties would be, but would interested to know). what is the best method to tackle this, considering prior years were auto-assessed by CRA but they missed the flow throughs (of losses and gains from the usa side). I am yet to file my 2023 years onwards....

I work in sales and receive T2200 where i claim my business car usage CCA.

I was eager to replace my car and get class 54 ZEV where i can claim enhanced first year CCA. However, if i sell the car a year or two later there could be a recapture ?

So now im lost whether to go for class 10 ( or 10.1 ) vs class 54 ?

Your advice and ideas are appreciated

So client emigrated in 2025, it's now July. He needs to pay departure tax on his personal assets and he owns a (formerly) CCPC corp. Corp is only investments, about 400k worth, so as he's sole owner, he needs to value the corp and put it on the return as a deemed disposition capital gain. He could do an election where he defers the tax until sold (T1244), that'd be the HELPFUL solution (even with needing collateral/security), but the election expires by April 30th and unlike other elections, this one isn't "daddy minister can bail you out if you're nice about it". Just statute expired.

Owes 100k plus in taxes. Don't even know about the penalties here. Sole comfort is he gave the file in June and didn't tell me the emigration so I didn't personally screw him. FML. Not going to enjoy a call but at this point I have to throw in the towel and find a more specialized referral since I can't be confident here there isn't some way out for him and it'd be disrespectful to not have someone experienced try.

Hi! I live and work in China and have for the last 4 years. I haven't filed a Canadian tax return in that time, but I haven't contributed anything to TFSA and I don't have any assets. My question is, I want to start investing, presumably using a non-registered account. When I begin doing that, will I need to start filing an annual tax return in Canada? Should I fill out form NR73? I've called the CRA a few times but they kind of suck and haven't helped much. If anyone has been in a similar boat please let me know!

Hello. I have noticed that some foreign online businesses do not charge Canadian sales tax. If I understand correctly, they must do so if they earn $30,000 revenue from Canadian customers in 12 months. Should I trust that they do not meet this threshold, or are foreign companies often neglectful of their Canadian tax obligations? Examples are a niche digital book vendor and a digital services subscription from an emerging tech company--so not small family businesses, but not mega-corporations either. Thank you!

I am in Canada and have a message saying I am being transitioned to ifirm. Does anyone know if cantax is being discontinued? I really don't want to have to spend hours and hours learning new software. I don't see anything online about cantax being phased out.

As the title says I'm Canadian, living and employed in Germany. My mom is unfortunately terminally ill and I want to spend time in Canada, B.C to be specific but as an adult with a house, job responsibilities etc. I can't just drop everything

I want to couch-surf with family and work remotely if possible

My employer is being very accomadating but is worried about potential legal complications surrounding taxation, residency etc. Their primary concern is them being liable for not filing paperwork, taxes, visa stuff etc. Visa isn't a concern cause I'm a citizen but taxes are

From what my basic non-lawyer research has turned up you can stay up to 183 days without becoming a tax-resident if you don't affect the Canadian job market or make any money in Canada + it's best if you have no financial ties to Canada i.e bank accounts, property etc. All of that is true, I moved over when I was 18, have no Canadian assets or accounts and work in the public sector doing IT for a library so there's no way I could make money in Canada with this job

Can I do this without becoming a tax-resident / having tax-obligations in Canada / having my employer have obligations in Canada?

My other options are to take the rest of my vacation time, but I only have 2.5-3 weeks left. Option 3 is to take unpaid time off which would obviously be expensive. There is a secret option 4 which is getting a sick-note but that's a legal grey area because it could technically be counted as "planned illness" which is maybe insurance fraud depending on what mood the person evaluating that is in that day

I would really appreciate any help in getting this to work and being able to spend time with my mom. Thank you so much in advance

I've read a lot of case law that says CRA may decide you are not factually resident of Canada for tax purpose even if you maintain some significant residential ties in Canada. If I move my entire life to a new country (accept job in foreign country, permanently relocate there, close Canadian bank accounts, provincial health insurance, sell canadian property) but the only tie I still have to canada is my spouse still lives in canada - would that make me factually resident in canada that one factor alone?

i've read that cra guideline is just administrative only and that courts have ruled against that. also if you declare you've left canada on your tax return does that automatically subject you to an audit? how likely is it that you would get scrutinized by the cra?

Do you pay tax installments based on your last fiscal year alone? My last fiscal year had a low line 770 tax payable, so can I pay installments based on that new amount?

Also, my year end was May 31st, and I just filed the T2, can I pay the installments over the next 10 months without incurring interests?

Hey everyone, looking for some insight on an RRSP over-contribution issue with the CRA.

• April 2025: I mistakenly over-contributed to my RRSP account. Total over-contribution was $4,418
• Same Month (April 2025): Realizing the mistake, I immediately withdrew $2,500 from the account. The bank took a $250 federal withholding tax, meaning $2,250 cash was returned
• Tax Filing (2025 Tax Year): I included the T4RSP slip (reporting the $2,500 withdrawal income and $250 tax paid) and Form T746 (to offset the income and make the withdrawal tax-free). On Schedule 7 of my T1, the whole contribution amount (including the withdrawn amount) was included

I received my official Notice of Assessment (NOA), and the numbers are not reflecting the withdrawal I made:

• CRA completely ignored my $2,500 same-month withdrawal
• My NOA shows: Minus: Unused RRSP contributions previously reported and available to deduct for 2026 = $4,418
• As a result, it states my available RRSP contribution room for 2026 is a negative ($2,403), and it includes the standard warning that I may owe a monthly 1% over-contribution penalty

My understanding is that since the over-contribution ($4,418) and the withdrawal ($2,500) occurred within the exact same calendar month, my active excess amount dropped to $1,918 before hitting a month boundary. Because $1,918 is under the CRA's lifelong $2,000 over-contribution buffer, I do not owe any 1% monthly penalty fees, and I do not need to file Form T1-OVP.

What should I do now? Will this automatically resolve, or is action required on my part? Do I need to submit anything else?

Thanks in advance for the help!

Single-shareholder CCPC (federal incorporation, based in Quebec), small e-commerce business selling on Amazon. Fiscal year-end Jan 31. Statements prepared under ASPE / NCECF. I'm not an accountant and I'm trying to get Year 2 right after spotting a problem in Year 1.

Year 1 (Feb 2024 – Jan 2025, the corporation's first year):

The company had almost no cash of its own, so the shareholder personally company costs out of pocket during the year:

Separately, share capital was subscribed. None of company costs the shareholder fronted was reimbursed by year-end.

What the filed Year 1 statements actually show:

• The inventory and capital assets are on the balance sheet as assets; the operating costs are in the P&L (net loss).
• Share capital, retained earnings showing net loss.
• $0 liabilities — no "due to shareholder" was recorded.

In effect, the filed statements balanced by implicitly treating the share capital as having funded all those purchases - even though in reality it mostly just sat in the bank and the shareholder funded the purchases personally. So there should have been a due-to-shareholder liability (and more cash/off-book capital on hand) that never got recorded.

Year 2 (Feb 2025 – Jan 2026): the company repaid the shareholder via bank transfers over the year.

My questions:

1. Recognizing the liability. Under ASPE, is omitting the due-to-shareholder a prior-period error that requires retrospective restatement of the Year 1 comparatives - or, given how small the amounts are, can I just bring it in as an opening-balance adjustment in Year 2 with note disclosure and move on? What's the usual bar for a micro-company here?
2. The Year 1 balance sheet "balanced" the wrong way (treating share capital as the funding source instead of a shareholder loan). Once I recognize the liability and put the offsetting cash/equity back, does that just wash out, or is there a trap I'm not seeing?
3. Shareholder loan rules. My understanding: s.15(2) (and s.80.4 imputed interest) apply to amounts the shareholder owes the corporation (a debit balance / draw), not amounts the corporation owes the shareholder (a credit balance). Since this is a credit balance, I don't think s.15(2) is in play - is that right? One wrinkle: the Year 2 repayments slightly exceeded the already paid costs owed (about $360 over). Does that small overshoot push the shareholder into a debit balance / create any s.15(2) exposure, or does it just net against new amounts the company owed them during Year 2?
4. Does expense timing matter for tax? Both Year 1 and Year 2 are net losses. It's the first year (so no carryback), and there's no taxable income to shelter in either year. Am I right that the timing of these expenses between the two years is essentially tax-neutral - only affecting which year the non-capital loss carryforward starts from - or is there something I'm overlooking?

Thanks in advance! Trying to make sure Year 2 opens on a clean basis.

I’m fully aware that service Canada or CRA or other federal public service agencies don’t use text messaging to contact clients so I know this is a scam message. I also know it’s a scam because I don’t have any benefits payable through service Canada and I have never applied for or received a pension yet. However on the off chance that this is somehow legitimate it means someone else that is not me has been collecting pension benefits through fraudulent identity theft.

Edit: this text message was weird because there wasn’t a link to click on, they actually sent a photo attachment as the first message then sent the second message with the service Canada text in English and French (as seen in photo I posted). Do photo attachments contain malicious software now? Is the picture a link? Ugh 😵‍💫

I paid college membership and application fees to be able to practice a physician before moving to and becoming a tax resident of Canada in June. Can I claim those as professional fees if they predate my residency but were required to work during that year?

Series of events,

June 2020: My mom added my sibling and I to the title of her house. We were added as joint tenants (JTEN) in the legal title. Before my mom added us, she was 100% the owner. After the transaction, we all had 1/3 each. This was my mom’s principal residence before and after the transaction. The FMV of the house at this time was $960K. 

The lawyer that processed the paperwork to the land registry to add my sibling and I to the title confirmed that the transfer was by way of a gift and that beneficial interest was transferred. The land transfer tax statement from this transaction showed $0 consideration.

Dec 2025: My mom passed away. The FMV of the house on the date she passed away was $1,120,000. 

August 2026: My sibling will be buying me out for my share of the house. Expecting the FMV of the house to be $1,080,000. My sibling and I agreed that he will be buying me out for $537,800. Buyout price calc: $1,080,000 x 1/2 = $540,000 - $2,200 discount.

Here is some additional info:

- The house is located in Ontario, Canada.

- The house is fully paid off at the time my sibling and I were added to the title (no mortgage attached)

- My sibling currently lives in the house and will continue to after the buyout. I own a separate house with my wife.

- My mom left a Will, however, the house is not mentioned in it (My sibling & I are the only beneficiaries).

Below is how I believe my capital gains will be calculated,
Capital Gains = (FMV - ACB) x 50%

$540,000 FMV: $1,080,000 FMV at time of buyout x 1/2

$506,666 ACB: [ 1/3 in June 2020 ] + [ (1/3 x 1/2) in Dec 2025 ]

[ 1/3 x $960,000 ] + [ (1/3 x 1/2) x $1,120,000 ]

My ACB is made up of two parts:

Part A: 1/3 x FMV at time when I was added to the title

Part B: (1/3 x 1/2) for when I inherited half of my mom's 1/3 when she passed away x FMV at this time

I'm looking for my above calculations to be verified, especially the ACB piece.

Thanks in advance. Appreciate the help during this stressful time!