In light of the wording of ITA s. 153(1)(g) and Reg. 200(2), there is a broad range of inappropriate circumstances where the issuance of a T4A is required – for, example, where a corporation pays an amount greater than $500 to its accountant for professional services. As another example, in 2015 CRA required the issuance of a T4A respecting fees paid by a dentist to professional advisors. What is the current status of the CRA study (referenced by it at the 2011 APFF Conference) of administrative practices respecting T4As? Can CRA provide an exemption from the requirement for issuing a T4A where the invoice for the services rendered (whether by an individual or corporation) bears a valid tax number (e.g., GST and QST registration numbers). CRA responded:
The CRA position remains unchanged regarding the requirement… in paragraph 153(1)(g)… .
[T]here is already administrative relief for the production of the T4A in specified limited circumstances such as:
i) where the payment made is less than $500, to the extent that no tax is withheld in respect of the amount, and
ii) where personal services are rendered to an individual by a professional or anyone else practising a trade, or if the services are rendered for the repair or maintenance of the principal residence of an individual.[N]o administrative relief, other than as stated in the previous paragraph, is available regarding payments made by an enterprise for services.