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Excise Tax Act (ETA) by virtue of new powers granted to the Minister under the  Time Limits and Other Periods Act (COVID-19) (Time Limits Act), which received royal assent on July 27, 2020. Statute-Barring Periods Under the ministerial orders, the period within which the CRA can issue reassessments was extended by six months or until December 31, 2020, whichever is earlier, in respect of years or periods that would otherwise have become statute-barred under the ITA or ETA on or after May 20, 2020. These ministerial orders are no longer in force and no further extensions have been announced...

AgraCity Ltd. v. The Queen, case study Will recent CRA tax court losses result in the toughening of transfer pricing rules? Lorne Saltman is a Partner with Gardiner Roberts LLP and the Head of the Tax Group. TORONTO – In a recent case in the Tax Court of Canada, the Minister of National Revenue failed to support a reassessment of AgraCity Ltd. (the "Taxpayer") under the transfer pricing rules of the Income Tax Act (Canada)(the "ITA").  The Taxpayer was part of a corporate group in Saskatchewan, the Farmers of North America ("FNA"), that was established to act as agent to purcha...