The CRA has introduced temporary e-submission process updates & other key guidance
The CRA has introduced temporary electronic submission processes to expedite urgent requests for certain international waivers, section 116 certificates of compliance and clearance certificates. Affected taxpayers who made submissions after March 12, 2020 should review these new processes to determine whether they should resubmit requests or documentation, or follow any additional procedures. The CRA has generally implemented these temporary processes following COVID-19 related restrictions affecting CRA access to previous submissions sent by mail or fax.
The CRA's new procedures, which allow taxpayers to submit requests and documentation to new dedicated CRA email accounts, will be of interest to those seeking Regulation 102 and Regulation 105 waivers, non-resident employer certification or section 116 compliance certificates. Similarly, legal representatives will be interested in the CRA's new dedicated email submission process to request clearance certificates.
International waivers and notifications for certificates of compliance
Rather than paper mail or fax, the CRA asks taxpayers to electronically submit the following urgent requests, as part of a new temporary procedure:
International waivers (Regulation 102, Regulation 105, and RC473, Application for Non-Resident Employer Certification waiver requests)
Requests for a certificate of compliance under section 116 (T2062, T2062A, T2062B, T2062C forms).
Supporting information, as applicable.
While processing times may be longer than usual, the CRA is continuing to review international waivers and requests for a certificates of compliance. The CRA notes that it may not be able to access any documents previously sent by mail or fax after March 12, 2020, due to its current restrictions on mail operations.
Requests for Individual Tax Numbers (ITNs)
The CRA is not currently processing applications for ITNs alongside taxpayers' waiver applications or requests for certificates of compliance. Instead, taxpayers are advised to complete an ITN request separately by completing Form T1261, Application for a Canada Revenue Agency Individual Tax Number (ITN) for Non-Residents and following the mailing instructions on the form.
The CRA encourages legal representatives to resubmit clearance certificate requests or supporting documentation sent after March 12, 2020. This general guidance comes as clearance certificate requests and documents sent by mail or fax to the CRA before this date may not be included in inventory for processing, due to limited office access by CRA employees during COVID-19. Re-submissions should be sent either through the CRA's Represent a Client or to a new email set up by the CRA for this purpose. While clearance certificates continue to be processed (i.e., Forms TX19, Asking for a Clearance Certificate and GST352, Application for a Clearance Certificate (under section 270 of the Excise Tax Act)), this new email process is a temporary solution to difficulties resulting from COVID-19, it will continue to be used until further notice.
For more information, contact your KPMG advisor.
Information is current to June 2, 2020. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500
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