Excise and GST/HST News - No. 78 (Fall 2010)

Table of Contents

Recapture of input tax credits (RITCs) filing requirements and elections

From July 1, 2010 until June 30, 2018, businesses whose taxable supplies are more than $10 million annually (including taxable supplies by associated persons) as well as certain financial institutions are required to repay or "recapture" all or some of the Ontario and British Columbia share of any available input tax credits (ITCs) for certain specified property or services (i.e., qualifying motor vehicles, including certain vehicle parts and services, and in Ontario, motive fuel other than diesel fuel for use in motor vehicles, specified energy; specified telecommunication services, specified meals and entertainment that are subject to an ITC repayment requirement of 50% under the general GST/HST rules).

The CRA has found that some large businesses are not reporting recaptured ITCs or are making errors concerning RITCs on their GST/HST NETFILE return. Common errors include:

Failing to report RITCs as and when required could result in tax liabilities and/or penalties.

Filing requirements

GST/HST registrants who are subject to the RITC requirements (large businesses) must file their returns using GST/HST NETFILE.

If you are reporting RITCs:

Other key factors to keep in mind include:

If you are not reporting RITCs:

If you need to amend a previously filed return:

Elections

Some optional methods of reporting recaptured ITCs are available. Registrants must file applicable election forms with CRA in order to use these optional methods.

A large business producing goods for sale (and carrying on such production activities primarily in Ontario or at least 10% in British Columbia) generally can elect to use a production proxy to determine what portion of the specified energy that it acquires for use in these provinces is considered to be used directly in the production of goods for sale (and not subject to the RITCs requirement). The election will have to be filed by the due date of the GST/HST return for the first reporting period in a particular recapture period and will generally apply for that entire recapture period. The election will remain in effect until revoked, and can only be revoked if used for a minimum of one recapture period. To make this election, use Form RC4530, Election or Revocation of an Election to use a Production Proxy to Report the Recapture of Input Tax Credits.

The Estimation and Reconciliation Method can be used to account for RITCs. To use this method, a large business must file Form RC4531, Election or Revocation of an Election to Use the Estimation and Reconciliation Method to Report the Recapture of Input Tax Credits.

A large business may file the election with the CRA in the following circumstances:

A GST/HST registrant cannot elect to use the Estimation and Reconciliation Method in a fiscal year, if that fiscal year is the registrant's first fiscal year.

Under the Estimation and Reconciliation Method, a large business will:

Further information

For further information on RITCs see GST/HST Technical Information Bulletin B-104, Harmonized Sales Tax - Temporary Recapture of Input Tax Credits in Ontario and British Columbia and GST/HST Notice249, Questions and Answers on the New Reporting Requirements for GST/HST Registrants. As well, the CRA Web site has dedicated Web
pages referencing this requirement. Go to "Temporary recapture of input tax credits (RITCs) requirement - Ontario and British Colombia" found at www.cra-arc.gc.ca/ritc , and Accounting for recaptured input tax credits (RITCs).

More information on the temporary RITC as it applies to selected listed financial institutions is in the Department of Finance Backgrounder, Financial Institution Rules for the Harmonized Sales Tax (HST), published with the May 19, 2010 Finance News Release, Proposed Changes to the Application of the Harmonized Sales Tax to Financial Institutions - May 2010 as well as the Department of Finance Backgrounder, Harmonized Sales Tax Rules for Financial Institutions, Interment Rights and Streamlined Accounting Methods, published with the June 30, 2010 Finance News Release, Proposed Changes to Certain Harmonized Sales Tax Rules in Respect of Financial Institutions, Interment Rights and Streamlined Accounting Methods available at www.canada.ca/en/department-finance.html.

Reminder - relief of the GST/HST on goods sold to Indians

Relief of the GST/HST is provided to Indian individuals under the Indian Act, as explained in GST/HST Technical Information Bulletin B-039, GST/HST Administrative Policy - Application of the GST/HST to Indians.

Goods sold by a vendor to an Indian individual are relieved of the GST and the full HST if the goods are sold on a reserve or are delivered to a reserve by the vendor or the vendor's agent. The purchaser is required to present proof of registration under the Indian Act (usually the Certificate of Indian Status, commonly known as an Indian Status Card) to the vendor in order to purchase the goods relieved of the GST/HST. The vendor is required to note on the invoice or other sales document that is retained by the vendor the registry number or band name and family number, a description of the qualifying property or service, and the date on which the credit was given.
 

For purchases in Ontario

Where the goods are purchased off a reserve and are not delivered to a reserve, relief of the GST/HST does not apply. However, in Ontario the Indian individual purchaser may be eligible for relief of the provincial part of the HST at the point of sale. The Ministry of Revenue of Ontario has announced that beginning September 1, 2010, GST/HST registrant suppliers in Ontario are allowed to credit status Indian purchasers (Indians, Indian bands and councils of an Indian band) at the time of sale with an amount equal to the 8% provincial part of the HST for qualifying off-reserve supplies of property or services. For further information on when the point-of-sale relief applies, see Ontario Guide80, Ontario First Nations Point-of-Sale Exemptions which is published under Ontario Harmonized Sales Tax Information Notice 7, Ontario First Nations Point-of-Sale Exemptions at www.rev.gov.on.ca under the heading "Forms and Publications".

The CRA processes GST/HST registrant suppliers' claims for a credit in respect of amounts that they have credited to status Indian purchasers at the point of sale. For information on how a GST/HST registrant supplier would report the HST on qualifying off-reserve supplies of property or services for reporting periods ending on or after September 1, 2010, and how the amount credited at the point of sale should be shown on invoices, please see GST/HST Info Sheet GI-106, Ontario First Nations Point-of-Sale Relief - Reporting Requirements for GST/HST Registrant Suppliers.

Exemptions under the GST/HST for training provided to individuals with a disorder or disability such as autism

Many supplies of training for children and adults with a disorder or disability such as autism are exempt of the GST/HST. The exemption applies to training that is specially designed to assist an individual cope with the effects of a disorder or disability or to alleviate or eliminate those effects. In order for such specially designed training to be exempt, it must be provided to an individual with a disorder or disability, or to another individual who provides personal care or supervision to that individual otherwise than in a professional capacity, such as a parent or guardian and

Finally, in order to be exempt, this training must not be similar to training ordinarily provided to individuals (or to their parents or guardians) who do not have the disorder or disability, such as general fitness or nutritional training.

Example

A family receives funding from a province to assist them in acquiring services of an Intensive Behavioural Intervention program for their child with autism. The supply of the services by the provider is exempt of the GST/HST.

In addition to the above training, training provided to individuals with a disorder or disability such as autism will be exempt of the GST/HST if it is provided by:

For more information on how the GST/HST applies to specially designed training for individuals with a disorder or disability, such as autism, please contact GST/HST Rulings at 1-800-959-8287.

Letter of good standing for claiming the Ontario and British Columbia provincial transitional new housing rebates

Builders of newly constructed or substantially renovated housing in Ontario and British Columbia (B.C.) may be entitled to claim a provincial transitional new housing rebate to recover the estimated Ontario retail sales tax or the estimated B.C. provincial sales tax embedded in the cost of housing that was completed in full or in part before July 2010.

The CRA would like to remind builders that they have to attach a letter of good standing to their rebate application when they submit this application for the first time.

The CRA has noted that many builders have not attached a letter of good standing to their rebate application. The CRA will not process a provincial transitional new housing rebate application and will return it to the builder if:

This letter is issued to builders by the governments of Ontario and B.C. and it remains valid for one year, unless the letter is revoked by the province. Ontario and B.C. determine the circumstances under which a letter of good standing is issued.

For more information please see Notice258, Reminder - Letter of Good Standing for Claiming the Ontario and British Columbia Provincial Transitional New Housing Rebates. For more information on the conditions for claiming a provincial transitional new housing rebate and calculating the amount of the rebate, refer to GST/HST Info Sheet GI-096, Harmonized Sales Tax: Provincial Transitional New Housing Rebates for Housing in Ontario and British Columbia .

Reminder - 10-year time limit to make a taxpayer relief request under the Excise Tax Act

The CRA reminds GST/HST registrants that they have until December 31, 2010, to review their records and send in any requests for penalty and/or interest relief under the taxpayer relief provisions for a reporting period that ended in the 2000 calendar year.

Legislative changes to the taxpayer relief provisions in the Excise Tax Act (both for GST/HST and non-GST purposes) were implemented effective April 1, 2007 to limit the CRA's discretion to waive or cancel interest, the 6% penalty imposed under former section 280, the failure-to-file penalty under section 280.1, and non-GST related penalties, to requests for reporting periods that ended within any of the 10 calendar years preceding the calendar year in which the request is made. The 10-year time limit rolls forward every January 1.

Example

A taxpayer relief request made by a person (for GST/HST or non-GST/HST purposes) during the 2010 calendar year will only be eligible for consideration for a reporting period that ended in 2000 or subsequent calendar years. Due to the 10-year rolling time limit, a taxpayer relief request made on or after January 1, 2011, will not be eligible for consideration for a reporting period that ended in the 2000 or prior calendar years.

The taxpayer relief provisions give the CRA the flexibility to administer the tax system fairly. They allow for a common-sense approach in dealing with persons who, because of personal misfortune or circumstances beyond their control, are unable to meet their GST/HST obligations.

Examples of circumstances where relief from penalties and interest may be warranted include:

Taxpayers or their authorized representatives can make a taxpayer relief request by completing Form RC4288, Request for Taxpayer Relief and forwarding it to their local CRA office. A copy of this form is available from the CRA Web site at www.cra-arc.gc.ca/forms or by calling 1-800-959-2221. Alternatively, they can make a request by writing to their local CRA office and providing specific information about why they were not able to meet their tax obligations.

For more details on requesting relief from penalties and/or interest, see GST/HST Memorandum 16-3, Cancellation or Waiver of Penalties and Interest.

New public service bodies' rebate schedule for the provincial part of the HST

As of July 1, 2010, public service bodies resident in a participating province (Ontario, Nova Scotia, New Brunswick, British Columbia, Newfoundland and Labrador) that are claiming a rebate for the provincial part of the HST, have to complete the new provincial schedule, Form RC7066 SCH, Provincial Schedule - GST/HST Public Service Bodies' Rebate and attach it to their rebate application in order to claim the rebate.

For information on completing the rebate application and the provincial schedule, see "Completing the public service bodies' rebate application" and "Completing the provincial schedule" on the CRA Web site.

If you are a resident in more than one province, at least one of which is a participating province, you have to calculate the public service bodies' rebate for the provincial part of the HST based on the extent you intended to consume, use or supply property or services in the course of your activities in each participating province in which you are resident. For more information, see "How do I calculate the public service bodies' rebate?".

If you are not resident in a participating province you are not entitled to a public service bodies' rebate of the provincial part of HST. You would only be entitled to a public service bodies' rebate of the GST and the federal part of HST.

The following table is an abridged version of the one published
on the CRA "Public service bodies' rebates" Web page.
  Rebate factor for the provincial part of the HST Province of residence



PSB type
Rebate factor
for GST or
the federal part of HST


New Brunswick


Newfoundland*


Nova Scotia


Ontario


British Columbia
Municipality 100 % 57.14 % 0 % 57.14 % 78 % 75 %
University 67 % 0 % 0 % 67 % 78 % 75 %
School authority 68 % 0 % 0 % 68 % 93 % 87 %
Public college 67 % 0 % 0 % 67 % 78 % 75 %
Hospital authority 83 % 0 % 0 % 83 % 87 % 58 %
Facility Operator 83 % 50 % 0 % 50 % 87 % 58 %
External supplier 83 % 50 % 0 % 50 % 87 % 58 %
Charity 50 % 50 % 50 % 50 % 82 % 57 %
Qualifying NPO 50 % 50 % 50 % 50 % 82 % 57 %

* Selected public service bodies resident in Newfoundland and Labrador are entitled to claim a 50% rebate for the provincial part of the HST paid or payable on purchases used in non-selected public service bodies' activities. A selected public service body means a municipality, hospital authority, facility operator, external supplier, or the following when established and operated on a non profit basis: school authority, university, or public college.

To apply for the rebate, use Form GST66, Application for GST/HST Public Service Bodies' Rebate and GST Self-government Refund. Beginning July 1, 2010, PSBs resident in a participating province who are claiming a rebate for the provincial part of the HST have to complete the new Form RC7066 SCH, Provincial Schedule - GST/HST Public Service Bodies' Rebate and attach it to their rebate application in order to claim their rebates.
For more information please see the CRA Web page "Public service bodies' rebates", CRA Guide RC4034, GST/HST Public Service Bodies' Rebate or CRA Notice253, Harmonized Sales Tax for Ontario and British Columbia - Questions and Answers for Public Service Bodies. Please note that registered PSBs can now use GST/HST NETFILE to electronically file their rebate application with their GST/HST return.

GST/HST seminars

The CRA offers various seminars including one on the GST/HST. These seminars have been designed to assist small businesses in understanding their tax responsibilities and to assist in developing an awareness of the services that the CRA provides. While these seminars are geared primarily towards new businesses, the information provided will also be of value to existing small businesses. To find out about the seminars offered by the CRA, please go to the "Events and seminars" Web page under the "Information about" heading on the CRA home page.

Paper Burden Reduction Initiative and the impact on small excise licensees

Bill C-47, the Sustaining Canada's Economic Recovery Act, received First Reading on September 30, 2010. This Act introduces measures to reduce the paperwork burden for small excise taxpayers under the Paper Burden Reduction Initiative (originally announced by the Minister of National Revenue on March 31, 2009.)

Please note that these measures will come into force on the date of Royal Assent of Bill C-47.

Currently, excise licensees and designated air carriers are required to file a return each fiscal month, except for certain small excise tax licensees. Licensed brewers are required to file a return every calendar month. This initiative will give eligible small excise licensees and designated air carriers the option of filing returns every six months instead of every month.

The proposed measures will apply to:

Fiscal half-year
Generally, the "fiscal half-year" will be based on a six-month period, or the person's fiscal year. However, for licensed brewers under the Excise Act, the six-month periods will be the first half and the second half of the calendar year.

Authorized reporting period of a fiscal half year

For licensees under the Excise Act, 2001
For licensees under the Excise Act, 2001 (i.e., excise warehouse licensees who do not hold in their excise warehouse manufactured tobacco or cigars, spirits licensees, wine licensees, and licensed users), there are specific rules for calculating the eligibility threshold in order to be authorized to use the fiscal half-year reporting period.

These particular licensees may apply to the CRA in a prescribed manner to be authorized to use the fiscal half-year reporting period and will be subject to the following specific eligibility rules:

Designated air carriers and excise tax licensees
Generally, designated air carriers and excise tax licensees under the Air Travellers Security Charge Act, and the Excise Tax Act may apply to the CRA in a prescribed manner to be authorized to use the fiscal half-year reporting period.

The person may be eligible for a fiscal half-year reporting period if:

Licensed brewers
Generally, licensed brewers under the Excise Act may apply to the CRA to be authorized to use semi-annual (six-month) reporting periods that are the first half and the second half of the calendar year.

The brewer may be eligible for a six-month reporting period if:

Revocation of fiscal half-year reporting period
An authorization to have a fiscal half-year or six-month reporting period will be deemed to be revoked

Generally, the revocation will become effective as of the first day after the end of the six-month period in which the excess occurs. However, for an excise warehouse licensee who begins to hold manufactured tobacco or cigars, revocation occurs as of the first day of the fiscal month in which the licensee begins to hold the tobacco or cigars.

Revocation will also occur when

The CRA will send a notice in writing of the revocation to the person and will specify in the notice the fiscal month, or calendar month in the case of brewers, for which the revocation becomes effective.

More information
The CRA will be publishing further notices to provide more detailed information.

New stamping regime for tobacco products

On July 12, 2010, the Jobs and Economic Growth Act received Royal Assent. This Act contains the legislative amendments to the Excise Act, 2001 required to implement a new stamping regime for tobacco products in order to enhance the integrity of the tobacco taxation system and to combat the contraband tobacco market.

On September 1, 2010, the new stamping regime came into effect. As of April 1, 2011, all tobacco products entered into the duty-paid market or released under the Customs Act and destined for the duty-paid market must be stamped with the new excise stamp. To facilitate compliance with this requirement, the stamp was introduced with the transition period of September 2010 to March 2011.

A major feature of the new stamping regime was the development of a new excise stamp with visible features and overt and covert security features similar to those used in banknotes and passports as shown in the figure below.
 

Image of stamp

Some of the visible features are: the size (20 × 40 mm), an indication of the type of tobacco product (e.g., 25 cigarettes, 200 cigarettes, 250 grams of tobacco and other amounts), a unique alphanumeric identification number, and the federal duty paid status bar. Some of the overt security features are: colour shift ink, ultraviolet visible ink, and an intaglio latent image - an engraved image that creates features that have unique tactility and visual effect.

The Excise Act, 2001 specifies that excise stamps may only be issued and in the possession of tobacco licensees and prescribed persons.

The CRA has issued two notices to introduce the new stamp and explain its security features: EDN24, New Stamping Regime for Tobacco Products, and EDN26 New Excise Stamp Security Features. Additional notices will be issued to explain the process for ordering excise stamps as well as the process for applying to become a "prescribed person". Please go to the CRA Excise Duty Notices Web page which will be updated as these new notices are published.

Please note that the excise stamp must be affixed in accordance with the proposals to amend the stamping regulations issued on September 14, 2009. For more information on the new stamping regime for tobacco products, see the CRA news release, New tobacco excise stamp on cigarette packages "One step closer against tobacco contraband", released on September 14, 2009, and fact sheet, Proposed amendments Enhanced stamping regime for tobacco products.

Prescribed rates of interest

The prescribed annual rate of interest in effect from October 1, 2010 to December 31, 2010, on overdue amounts payable to the Minister is 5%. The prescribed annual rate of interest on amounts owed by the Minister (i.e., rebates or refunds) is 1% for corporate taxpayers and 3% for non-corporate taxpayers. These rates are applicable to income tax, excise tax, the softwood lumber products export charge, GST/HST and the air travellers security charge (ATSC) and excise duty on wine, spirits and tobacco.

The prescribed annual rate of interest respecting excise duty on beer, on overdue amounts payable for the indicated period, is set at 3%. Refund interest rates are not applicable for amounts owed by the Minister (i.e., rebates or refunds) for excise duty that is in relation to beer.

Prescribed rates of interest
  Income Tax, Excise Tax,
Softwood Lumber Products Export Charge, GST/HST and ATSC, Excise Duty (wine, spirits, tobacco)
Excise Duty
(beer)
Period Refund Interest Arrears and Instalment Interest Arrears
Interest
October 1 to December 31, 2010 1% corporate taxpayers
3% non-corporate taxpayers
5% 3%
July 1 to September 30, 2010 1% corporate taxpayers
3% non-corporate taxpayers
5% 3%
April 1 to June 30, 2010 3% 5% 3%
January 1 to March 31, 2010 3% 5% 3%

Prescribed interest rates for previous years are available on the CRA Web site at www.cra.gc.ca/interestrates.

What's new in publications

The following is a list of new or revised excise and GST/HST forms and publications. As a result of the HST in Ontario and British Columbia, CRA forms and publications are constantly being updated. Please check the CRA "What's new" Web site often for the most current versions.

GST/HST forms

GST44 - Election Concerning the Acquisition of a Business or Part of a Business
GST59 - GST/HST Return for Imported Taxable Supplies and Qualifying Consideration
GST66 - Application for GST/HST Public Service Bodies' Rebate and GST Self-government Refund
GST190 - GST/HST New Housing Rebate Application for Houses Purchased from a Builder
GST497 - Election under the Special Attribution Method for Selected Listed Financial Institutions and Notice of Revocation
GST521 - GST/HST Multi-Employer Pension Plan Trust Rebate Application
GST523-1 - Non-profit organizations - Government Funding
GST531 - Return for Self-Assessment of the First Nations Goods and Services Tax (FNGST)
RC4601 - GST/HST Reporting Entity and Tax Adjustment Transfer Elections and Revocations for a Selected Listed Financial Institution
RC4602 - Request for a Group GST/HST Registration Number for Selected Listed Financial Institutions with Consolidated Filing
RC4603 - GST/HST Tax Adjustment Transfer Election and Revocation for a Selected Listed Financial Institution
RC4604 - GST/HST Reporting Entity, Consolidated Filing and Tax Adjustment Transfer Elections and Revocations for a Selected Listed Financial Institution
RC4605 - Total Tax Recovery Rate Election and Revocation for a Selected Listed Financial Institution
RC4606 - Election or Revocation for a Qualifying Small Investment Plan to be Treated as a Selected Listed Financial Institution
RC4607 - GST/HST Pension Entity Rebate Application and Election

GST/HST info sheets

GI-096 - Harmonized Sales Tax: Provincial Transitional New Housing Rebates for Housing in Ontario and British Columbia
GI-101 - Harmonized Sales Tax: Information for Non-registrant Builders of Housing in Ontario, British Columbia and Nova Scotia
GI-102 - Nova Scotia HST Rate Increase: Sales and Rentals of Non-residential Real Property
GI-103 - Nova Scotia HST Rate Increase: Progress Payments and Holdbacks
GI-104 - Nova Scotia HST Rate Increase: Sales and Rentals of New Housing
GI-108 - Applying the 2010 Nova Scotia HST Rate Increase - Personal Property
GI-109 - Applying the 2010 Nova Scotia HST Rate Increase - Services
GI-110 - Applying the 2010 Nova Scotia HST Rate Increase - Admissions and Memberships
GI-111 - Applying the 2010 Nova Scotia HST Rate Increase - Transportation Services and Passes

GST/HST notices

Notice253 - Harmonized Sales Tax for Ontario and British Columbia -  Questions and Answers for Public Service Bodies (revised)
Notice257 - For discussion purposes only: The GST/HST Rebate for Pension Entities
Notice258 - Reminder - Letter of Good Standing for Claiming the Ontario and British Columbia Provincial Transitional New Housing Rebates
Notice259 - Information Requirements Related to Investments in Selected Listed Financial Institution Distributed Investment Plans (other than Exchange-traded Funds)

Excise tax and special levies forms

B200 - Excise Tax Return
N15-1 - Excise Tax Act, Application for Refund/Rebate, Supplementary Information

Excise duty notices

EDN25 - Sale of Unstamped Partially Manufactured Tobacco and Activities of a Tobacco Licensee
EDN26 - New Excise Stamp Security Features

Air travellers security charge forms

B253 - Softwood Lumber Products Export Charge - Registration Form
B253-1 - Softwood Lumber Products Export Charge - Independent Remanufacturer Registration Supplement
B253-2 - Softwood Lumber Products Export Charge - Registration Supplement - Multiple Regions or Mills
B275 - Softwood Lumber Products Export Charge Return

Softwood lumber products export charge notices

SWLN29 - Surge Charge - Alberta Region (August 2010)
SWLN30 - Notice to Independent Remanufacturers - Calculation of the Yield Loss Percentage
SWLN31 - Surge Charge - Alberta Region (September 2010)
SWLN32 - Surge Charge - Alberta Region (October  2010)

All GST/HST, Excise Duty, and Excise Taxes and Special Levies publications can be found on the CRA Web site at www.cra.gc.ca/gsthsttech, at www.cra.gc.ca/etsl, and at www.cra.gc.ca/exciseduty.

Enquiries

For online access to account balances, transactions, notices and more for your GST/HST, softwood lumber products export charge,
air travellers security charge as well as excise taxes and duty accounts, go to www.cra.gc.ca/mybusinessaccount.
For general information and to make enquiries regarding your account (except for softwood lumber products export charge accounts), call Business Enquiries at 1-800-959-5525.
For enquiries regarding your softwood lumber products export charge account, call 1-800-935-0313.
To make enquiries regarding the status of specific GST/HST domestic rebate claims, call 1-800-959-5525.
For GST/HST technical enquiries call GST/HST Rulings at 1-800-959-8287.
Forms and publications
To access forms and publications online visit www.cra.gc.ca/orderforms.
To order forms and publications by telephone call 1-800-959-2221.
Are you a GST/HST registrant located in Quebec?
To make an enquiry or obtain information on the GST/HST, contact Revenu Québec at 1-800-567-4692 or visit their Web site at www.revenu.gouv.ca.

The Excise and GST/HST News is published quarterly and highlights recent developments in the administration of the goods and services tax (GST) and harmonized sales tax (HST), First Nations goods and services tax (FNGST) and First Nations tax (FNT), softwood lumber products export charge, air travellers security charge (ATSC) as well as excise taxes and duties. If you would like to receive a link to each new edition of the Excise and GST/HST News as it is published, subscribe to the electronic mailing list.

This publication is provided for information purposes only and does not replace the law, either enacted or proposed. Please note that any commentary in this newsletter regarding proposed measures should not be taken as a statement by the CRA that such measures will in fact be enacted into the law in their current form. Comments or suggestions about the newsletter should be sent to the Editor, Excise and GST/HST News, Legislative Policy and Regulatory Affairs Branch, CRA, Ottawa, ON K1A 0L5.

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