Filed your 2019 Personal Income Tax Return: Now what?

What an absolute crazy year 2020 has been thus far!

The tax filing deadline for individuals to file their 2019 personal income tax returns (T1) in Canada was June 1st, by 11:59pm. For Canadians who have earned self-employment income, their returns are due by June 15th, 2020. Payments for balances owing are due to the CRA by September 1st, 2020, and the CRA is currently not charging interest on exsting balances owing the them, nor interest or penalties for any late payments or filings for the time being.

New and enhanced services

Check CRA processing times – Want to find out quickly how long it will take for the CRA to process your return, or your refund? Use the Check CRA Processing Times tool on canada.ca to get a targeted completion date. The new tool uses published service standards and information you select from drop-down menus to calculate targeted completion times for various programs.

Dedicated telephone service for tax service providers – If you are still working on a tax return(s), the CRA have been offering this service to small and medium income tax service providers across Canada for the 2020 tax filing season. By using this service, income tax service providers can connect with experienced CRA officers who assist with complex tax questions.

Representative authorizations – Thank goodness, the CRA has created a new e-authorization process for online access to individual tax accounts which permits representatives to request access to individual tax accounts using a web form through Represent a Client. As a result, the existing T1013 form will be discontinued for access to individual tax accounts.

The T1013, RC59, and NR95 will be combined into one form called the AUT-01 Authorize a Representative for Access by Phone and Mail. This form will only be used to request offline access to individual and business tax accounts.

Owing Money to CRA

If you have filed, or are about to file and you owe money to the CRA, there are a couple of critically important facts you should keep in mind.

  1. If you have applied for any of the COVID-prompted benefit programs, and have done so through Direct Deposit, you may, unfortunately, be at risk.
  2. The CRA is delaying the payment of balances owing until September 1st, while not charging interest on all accounts except payroll accounts. This shouldn’t mean its okay to forget it until the fall, but rather, with no interest being charged on existing balances, its the best time to figure out ways to catch up, set aside funds, or find / earn funds to pay off the CRA
  3. Before we all know it, it will be September, and a few things will be certainties. Our year-end will be fast approaching for the 2020 tax filing season, any balances owing to the CRA will be due, and the Canadian debt and deficit will be through the roof. The Federal government will need those funds ASAP, and aside from raising taxes, they will likely begin aggressive collections of taxes owing. The quickest way the CRA can recover funds, is by issuing a Notice of Assessment (which has legal warning in it) and then taking those funds from your bank account.
  4. You have options outside of bankruptcy, consumer proposals, high-interest loans, or high-rate mortgages. Preparing in advance for this situation and working with the CRA can prevent unwanted or unexpected surprises.

 

The CRA’s collections staff have already been advised where to locate direct deposit information and how ensure it is accessible when full collections are permitted.

Don’t wait until it’s too late.

inTAXicating can assist with anything CRA-related. With over 10-years experience working in the CRA’s Collections department, we know things the CRA will never tell you.

 

Canada Emergency Commercial Rent Assistance (CECRA)

What is the Canada Emergency Commercial Rent Assistance Program (CECRA), and how does it work?

The CECRA program will provide forgivable loans to qualifying commercial property owners to cover 50% of three (3) monthly rent payments that are payable by eligible small business tenants who are experiencing financial hardship during April, May, and June.

The Program

The loans will be forgiven if the mortgaged property owner agrees to reduce the small business tenants’ rent by at least 75% under a rent forgiveness agreement, which will include a term not to evict the tenant while the agreement is in place. The small business tenant would cover the remainder, up to 25% of the rent.

Who Qualifies as a Small Business Tenant?

Impacted small business tenants are businesses who;

  • Pay no more than $50,000 in monthly gross rent per location (as defined by a valid and enforceable lease agreement),
  • Generate no more than $20 million in gross annual revenues, calculated on a consolidated basis (at the ultimate parent level), and
  • Have temporarily ceased operations (i.e. generating no revenues), or has experienced at least a 70% decline in pre-COVID-19 revenues.

Property Owners

CECRA for small businesses is applicable to commercial property owners with:

  • Eligible small business tenants
  • Eligible small business subtenants
  • Residential components and multi-unit residential properties with commercial tenants (i.e. mixed usage)

 

To qualify, property owners must meet the following requirements:

  • You own property that generates rental revenue from commercial real property located in Canada.
  • You are the property owner of the commercial real property where the impacted small business tenants are located.
  • You have a mortgage loan secured by the commercial real property, occupied by one or more small business tenants.
  • You have entered OR will enter into a rent reduction agreement for the period of April, May, and June 2020, that will reduce impacted small business tenant’s rent by at least 75%.
  • Your rent reduction agreement with impacted tenants includes a moratorium on eviction for the period of April, May and June 2020.
  • You have declared rental income on your tax return (personal or corporate) for tax years 2018 and/or 2019.

 

How Does it Work?

While it is expected that CECRA will be operational by mid-May, commercial landlords are expected to either enter into the agreement, reducing rent immediately, or, once the program details have arrived, enter into the agreement and refund the monies to the tenant.

 

What Will CRA be looking for?

In order to support the credit, the CRA will be checking to ensure revenue loss. Small businesses can compare revenues in April, May and June of 2020 to that of the same month of 2019. They can also use an average of their revenues earned in January and February of 2020. If these figures do not justify a revenue loss of at least 75%, the credit will need to be paid back to the CRA.

 

What will CMHC be looking for?

CECRA for small businesses loans will be forgiven if the property owner complies with all applicable program terms and conditions including to not seek to recover rent abatement amounts after the program is over.

 

Administering the Program

CMHC will administer the program on behalf of the Government of Canada, provincial and territorial partners.

 

The program offers assistance for the months of April, May and June, 2020.

  • It can be applied retroactively.
  • Property owners may still apply for assistance once the 3-month period has ended if they can prove eligibility during those months.
  • Property owners must refund amounts paid by the small business tenant for the period.

 

If rent has been collected at the time of approval, a credit to the tenant for a future month’s rent (i.e. July for April) is acceptable if agreed upon by both the property owner and the tenant. This can be a flexible 3-month period.

 

The deadline to apply is August 31, 2020.

 

Program Summary Details

CMHC will provide forgivable loans to eligible commercial property owners.

  • The loans will cover 50% of the gross rent owed by impacted small business tenants during the 3-month period of April, May and June 2020.
  • The property owner will be responsible for no less than half of the remaining 50% of the gross rent payments (paying no less than 25% of the total).
  • The small business tenant will be responsible for no more than half of the remaining 50% of the gross rent payments (paying no more than 25% of the total).