Single Administration of Corporate Tax

The governments of Canada and Ontario signed a Memorandum of Agreement on October 6, 2006, that will lead to the Canada Revenue Agency (CRA) administering certain Ontario corporate taxes.

Why are we making this change?

Ontario businesses will benefit from one form, one set of rules, one audit and one appeals process.

What does this mean for businesses?

Corporate taxpayers will start:

  • making blended instalment payments to the CRA in February 2008;
  • seeing compliance cost savings starting in April 2008, from integrated audits, objections, appeals and rulings for pre-2009 taxation years;
  • filing a single T2 Corporate Tax return (including the Ontario annual information return) with the CRA for taxation years ending after December 31, 2008.

The CRA will assume some responsibilities for taxation years ending before December 31, 2008 as a means of providing early compliance gains to business.

For now the Ontario Ministry of Finance continues to be your first point of contact for all matters related to your Ontario corporate tax account.

Beginning with the 2009 taxation year, the CRA will administer the following corporate taxes on behalf of Ontario:

  • Corporate income tax
  • Corporate minimum tax
  • Capital tax
  • Special additional tax on life insurers

Ontario will continue to administer:

  • Mining tax
  • Insurance premiums tax
  • Electricity Act payments-in-lieu of federal and Ontario corporate taxes

For tax years ending in 2009 or later, corporations that have a permanent establishment in Ontario will file a harmonized T2 Corporation Income Tax Return with the Canada Revenue Agency (CRA). The harmonized return will include the following Ontario corporation taxes: corporate income tax, including refundable tax credits, corporate minimum tax, capital tax, and special additional tax on life insurance corporations.

If a corporation's fluctuating fiscal period ends in January 2009 and it does not have a tax year ending in 2008, send your instalments and payments for the Ontario corporations tax to the Ontario Ministry of Finance for that fluctuating fiscal period. File a CT23 Corporations Tax and Annual Return or a Corporations Tax Return CT8 with the Ontario Ministry of Finance for that same fluctuating fiscal period.


Q. What are the benefits of single administration of corporate income tax for businesses that file in Ontario?

A. Single administration of Ontario's corporate income tax will lead to a more streamlined tax system for businesses that file in Ontario. Ontario businesses will benefit from a harmonized T2 corporate tax return (starting in the 2009 tax year), one set of rules, one audit, one objections and appeals process, one place to make a voluntary disclosure for corporate income taxes, and a single tax administrator.

This will save Ontario business up to $100 million a year in compliance costs and an additional $90 million in reduced corporate taxes due to Ontario adopting the federal tax base.


Q. What taxes are included under the single administration of Ontario corporate taxes?

A. Under the terms of the Memorandum of Agreement (MOA) that was signed in October 2006, the CRA will administer Ontario's corporate income tax, corporate minimum tax (CMT), the special additional tax on life insurers and the Ontario capital tax. 

Ontario will continue to administer the mining tax, insurance premiums tax, payments in lieu of corporate taxes and transfer taxes imposed under the Electricity Act, 1998.


Q. Which provincial functions will be assumed by the CRA under the single administration of Ontario's corporate tax?

A. Once the transition is fully implemented, the CRA will provide the same services to businesses that it currently provides to seven other provinces and all three territories.

These services include payments processing, returns processing, audit, objections and appeals, voluntary disclosures, rulings, and the collection of accounts receivable.


Q. Will the CRA have the expertise to properly administer Ontario's corporate income tax and answer clients' questions?

A. Yes. The CRA has extensive experience providing a responsive service to safeguard, administer and streamline tax programs for governments across Canada.

The CRA is committed to retaining subject matter experts from the province of Ontario for the transition to a single administration. Over 300 former Ontario employees have been hired by the CRA to help ensure a seamless transition to the CRA administration.


Q. When will the tranEsition to the CRA for the single administration of Ontario's corporate tax happen?

A. The CRA has already begun receiving combined federal and provincial instalment payments for the 2009 tax year.

On April 3, 2008, all of Ontario's corporate tax audit, objections, appeals and tax advisory/rulings functions for all pre 2009 taxation years were transferred to the CRA.

For taxation years ending on or after January 1, 2009, corporations will begin to file a single harmonized T2 Corporation Income Tax Return with the CRA, and the CRA will become the single point of contact for matters relating to Ontario provincial corporate income tax.


Q. Is the CRA maintaining the high level of service that Ontario taxpayers expected from the Ontario Ministry of Finance (MOF)

A. Yes, the CRA is maintaining the high level of service that Ontario taxpayers expect.

As a result of the April 3, 2008 transition Ontario businesses began seeing the benefits of the harmonized corporate tax system a full eight months before the introduction of the harmonized T2 return for the 2009 taxation year.

The transition has gone very well. Despite the anticipated challenges of the transition the CRA is processing inventories at a level that is consistent with the Ontario Ministry of Finance's historical workload.

The CRA is confident that service standards will be met for new workload claims and is prioritizing completion of the work in progress files (that were transferred from MOF to the CRA) to ensure that these also are processed in a timely manner.


Q. Where do I send my corporate tax return?

A. For taxation periods ending on or before December 31, 2008, you will file your Ontario CT23 income tax return with the Ontario Ministry of Finance and your federal T2 Corporation Income Tax Return with the CRA.

For taxation periods ending on or after January 1, 2009, you will file one harmonized T2 return with the CRA.


Q. Where do I call if I have a question regarding corporate income tax?

A. The Ontario Ministry of Finance remains your point of contact for all enquiries regarding your Ontario corporate tax account.

  • On the web – ontario.ca/finance
  • Toll free within North America
    • 1 800 262-0784
    • 1 800 263-7776 for teletypewriter
  • Outside North America - 905 433-6000

Q. In calculating and making my combined instalment payments, do I just add the amount I estimate for Ontario corporation income tax to the amount I estimate for federal and other provincial/territorial taxes?

A. Yes. When calculating your combined instalment payments for tax years ending in 2009 and later, please include the following Ontario corporation taxes:

  • corporate income tax;
  • corporate minimum tax;
  • capital tax; and
  • special additional tax on life insurers.

Q. Are there any instructions available for calculating the combined instalment payments?

A. Yes. You can find instructions and an example in the 2008 version of Guide T7B-CORP, Corporation Instalment Guide.

This guide includes the 2009 worksheets for Ontario:

  • T2WS4, Calculating estimated Tax Payable and Tax Credits for 2009 (Ontario);
  • T2WS5, Calculating monthly instalment payments for 2009 (Ontario), and
  • T2WS6, Calculating quarterly instalment payments for 2009 (Ontario).

The guide and the worksheets are available at www.cra.gc.ca/forms. Instructions, and more information on paying your taxes by instalments are on the Pay by instalments page.


Q. When the CRA assesses my harmonized 2009 T2 Corporation Income Tax Return, how will they be able to determine the instalment base correctly?

A. The CRA will determine the instalment base using the assessed 2009 T2 Corporation Income Tax Return and previous corporate tax information provided by the Ontario Ministry of Finance.


Q. If the CRA needs to verify the prior years Ontario corporation income tax in order to determine the 2009 instalment base, will it slow down the processing of the T2 Corporation Income Tax Return?

A. There will be no time delay in processing. Determining your 2009 instalment base will not affect the processing of your T2 Corporation Income Tax Return.


Q. I use software to file my T2 Corporation Income Tax Returns. When I'm ready to file my 2009 return, will the software include everything I need to compute Ontario tax and credits?

A. By January 2009, software packages for T2 returns and Schedules should contain the additional schedules and modified calculations you will need to fill out the new harmonized T2 return.


Q. Will the CRA provide all of the 2009 Ontario forms I need to calculate Ontario tax and credits? If so, when will they be available?

A. Yes. The CRA will provide all the 2009 Ontario forms you will need to file a harmonized T2 Corporation Income Tax Return for tax years ending in 2009 and later. These forms will be available on the CRA Web site by January 5, 2009.


Q. If a corporation has been audited by the Ontario Ministry of Finance in a previous year, does this exempt the CRA from auditing the same return again after the CRA has started administering Ontario's corporate income tax on April 3, 2008?

A. The CRA will not audit years that have already been audited. If the CRA makes adjustments to a federal return that impact a previously audited Ontario CT23, an adjustment to the CT23 will be processed, but the CT23 will not be re-opened for an audit.


Q. When will the CRA start issuing Corporation Notices of (Re)Assessment that include Ontario taxes and credits?

A. In April 2009, the CRA will start issuing Corporation Notices of (Re)Assessment for the 2009 tax year, that will reflect Ontario taxes and credits.


Q. Will the Ontario taxes and credits assessed as part of the harmonized T2 Corporation Income Tax Return be itemized on the Corporation Notices of (Re)Assessment?

A. Yes. The Corporation Notices of (Re)Assessment will display "net Ontario taxes/credits” as well as all separate tax/credit amounts used in the net provincial tax calculation. These tax and credit amounts will correspond with those displayed on the revised Schedule 5, (Code 0802, Tax Calculation Supplementary – Corporations, (2008 and later tax years and Ontario 2009).


Q. If I would like to adjust a CT23 Ontario Corporations Tax Return I filed for a taxation year before 2009, where do I send my request?

A. You should send your adjustment request or amended return to the Ontario Ministry of Finance for pre 2009 taxation years.


Q. I sent my corporate tax return to the wrong organization. What will happen to it?

A. The CRA and the Ontario Ministry of Finance have developed procedures for forwarding misdirected mail. Your tax return will be redirected to the appropriate organization.


Q. Where do I go for all the forms and guides related to my Ontario corporate income tax return?

A. For now, you will obtain all forms and guides you will need to file your CT23 Ontario Corporations Tax Return from the Ontario Ministry of Finance.

As of January 5, 2009, you will be able to obtain all documents for filing the harmonized T2 return from the CRA.


Managing your debts

Q. My corporation has a corporate tax debt with the Province of Ontario. Will my existing payment arrangement be honoured once the CRA assumes administration of Ontario corporate tax? Will my corporate tax debt payments continue to go to Ontario, or the CRA?

A. If you currently have a payment arrangement in place with the Province of Ontario for any debts existing for tax years prior to 2009, they will remain in place and continue to be sent to the Ontario Ministry of Finance.

The CRA will only be taking payment arrangements on debts for tax years 2009 and subsequent, as these years will include both the federal and provincial portions of the corporate tax.


Q. My corporation has a corporate tax debt with the CRA. Will my existing payment arrangement be honoured and how will I make payments? Will my corporate tax debt payments continue to go to the CRA?

A. Yes. If you currently have a payment arrangement in place with the CRA for any debts existing for tax years prior to 2009, they will remain in place and continue to be sent to the CRA.


Q. My corporation currently has a corporate tax debt with both the CRA and the Province of Ontario. Will my payments continue to go separately to both organizations?

A. Yes. If you currently have a payment arrangement in place with both the CRA and the Province of Ontario for taxation debts for tax years prior to 2009, they will remain in place and continue to be sent separately to the respective governing authority.

The CRA will only be taking payment arrangements on corporate tax debts for tax years 2009 and later, as these years will include both the federal and provincial portions of the corporate tax.


Q. What do I do if I owe Corporations taxes for both 2008 and 2009?

A. You will need to make two separate payment arrangements.

All Corporation tax debts for years 2008 and prior remain the responsibility of the governing authority, namely the CRA or the Province of Ontario.

This means that, for these debts, you will continue to make separate arrangements, as you have in the past, with both the CRA and the province of Ontario.

Corporation tax debts for tax years 2009 and later will become the responsibility of the CRA.


Requesting Income Tax Rulings and Interpretations

Q. Where do I send my request for an advance tax ruling or a technical interpretation under the Ontario Corporations Tax Act or Taxation Act, 2007?

A. Following the transition that took place on April 3, 2008, you should send your requests for advance tax rulings to the CRA.

Contact information and other information about the CRA Income Tax Rulings Directorate can be found in Information Circular 70-6R5, Advance Income Tax Rulings.


Q. I have sent requests to the Ontario Ministry of Finance for advanced tax rulings and technical interpretations on behalf of my clients. Who can I contact for information on the status of those requests?

A. On April 3, 2008, the CRA assumed responsibility for all rulings and interpretations in progress with the Ontario Ministry of Finance. The CRA is contacting each person who submitted such a request to confirm the contact name and phone number of the CRA official who is responsible for their file.

If you have not been contacted by a CRA official please contact the Ontario Ministry of Finance for assistance.

  • On the web – ontario.ca/finance
  • Toll free within North America
    • 1 800 262-0784
    • 1 800 263-7776 for teletypewriter
  • Outside North America - 905 433-6000

Q. Will the CRA respond to telephone enquiries on Ontario tax matters?

A. The CRA Income Tax Rulings Directorate provides a telephone enquiry service to respond to specific questions based on interpretative positions previously taken by the CRA. Starting April 3, 2008, the CRA also began responding to specific questions based on interpretative positions previously taken by the Advisory Services and Program Policy Branch of the Ontario Ministry of Finance respecting the Ontario Corporations Tax Act and the Taxation Act, 2007.

For the contact number, and for other information about the telephone enquiries service offered by the CRA Income Tax Rulings Directorate, see Information Circular 70-6R5, Advance Income Tax Rulings.


Q. Will there be a delay in dealing with my request for an Ontario ruling or interpretation because it is transferred to the CRA?

A. The Income Tax Rulings Directorate will continue to make every effort to provide rulings and interpretations in accordance with its published service standards: see Information Circular 70-6R5, Advance Income Tax Rulings.

The Ontario Ministry of Finance's work-in-progress that was transferred to the CRA on April 3, 2008 has been prioritized to ensure that it is completed on a timely basis.  This will minimize the potential for delay resulting from the transfer of work from the Ontario Ministry of Finance to the CRA.


Q. The Ontario Ministry of Finance and the CRA have different fees in place for obtaining an advance income tax ruling. What fees will apply when the CRA is ruling on Ontario law?

A. For matters regarding taxation years prior to 2009, the Ontario Ministry of Finance's fees will continue to apply for advance income tax rulings issued under the Ontario Corporations Tax Act.


Q. Can I submit a single request to the CRA for advance tax rulings under both the federal Income Tax Act and the Ontario Corporations Tax Act or Taxation Act, 2007? What fees will be charged for the work done?

A. Yes, you can submit a single request.

The Ontario Ministry of Finance's fees will continue to apply for work done on issues related to the Corporations Tax Act or the Taxation Act, 2007.

The CRA's fees will apply for the work done that is related to Income Tax Act issues.


Filing Objections and Appeals

Q. Where will I file my Ontario Notice of Objection now that the CRA is administering the Ontario Corporations Tax Act following the April 3, 2008 transition?

A. Except for those related to Premium Tax (Corporations that file a CT8 Tax Return), all Notices of Objection will be filed with the CRA by delivering or mailing them to the Chief of Appeals at one of its Tax Services Offices or Tax Centres .  The objection form, ON100, is accessible through the CRA website in March 2008.

Applications to extend the time to file an objection under section 91 of the Act should be filed in the same manner. No special form is required to do this, but you must address a written request to the Chief of Appeals of your tax services office or tax centre, justifying your need for an extension.


Q. What happened to objections in progress at the Ontario Ministry of Finance on April 2, 2008?

A. Unresolved objections were transferred to the Appeals Division of the CRA Toronto East Tax Services Office. The Ontario Ministry of Finance sent a letter informing affected taxpayers of this in late March 2008.


Q. What about appeals in progress with the Ontario Ministry of Finance, that were before the courts on April 2, 2008?

A. The Ontario Ministry of Finance will continue to be responsible for the appeals in court on April 2, 2008 and any subsequent appeals arising from decisions on objections processed by the Ministry.


Q. If I disagree with the CRA's decision on my objection and decide to file an appeal before the Ontario Superior Court of Justice, who will be responsible for the appeal?

A. The CRA Appeals Branch will be responsible for the appeal and Justice Canada will represent the Province of Ontario in court.


Section 6 – Your Ministry of Government Services (MGS) Corporations Information Act Annual Return

Q. What is a Ministry of Government Services (Ministry of Government Services ) Corporations Information Act Annual Return.

A. The MGS Corporations Information Act Annual Return refers to information collected under the authority of the Corporations Information Act, to confirm director and officer information for Ontario corporations and to provide information on the Agent for Service for Extra-Provincial foreign corporations, for the purposes of maintaining a public database of corporate information.


Q. Am I required to file an MGS Corporations Information Act Annual Return?

A. Corporations subject to the Ontario Business Corporations Act, corporations subject to the Ontario Corporations Act and foreign corporations which have a licence endorsed under the Ontario Extra-Provincial Corporations Act, are required to file an MGS Corporations Information Act Annual Return.

More information can be found at www.serviceontario.ca


Q. Where will I file my integrated Corporations Information Act Annual Return?

A. Work is underway to develop regulations to allow you to file your integrated Annual Return as part of the T2 corporate tax return with the Canada Revenue Agency for taxation years ending on or after January 1, 2009.

Ontario corporations may still file their Annual Return as part of the Ontario CT23 corporate tax return with the Ministry of Finance for taxation years ending on or before December 31, 2008.


Q. If I have questions or want to make changes to my MGS Corporations Information Act Annual Return after it has been filed, whom should I contact?

A. Subject to approval of the regulations currently being drafted, you should contact the MGS at 416-314-8880, toll free at 1 800-361-3223 TTY 416-325-3408 or toll free at 1 800-268-7095.


Section 7 – Voluntary Disclosure

Q. As of April 3, 2008, what are the procedures, to make an Ontario corporate tax voluntary disclosure?

A. Effective April 3, 2008, the CRA is administering corporate tax voluntary disclosures on behalf of Ontario. All Ontario corporate tax disclosures (for pre and post harmonization taxation years) will follow the procedures outlined in the CRA's voluntary disclosures policy.

www.cra-arc.gc.ca/voluntarydisclosures


Q. How will the transition to single administration affect the way I make an Ontario corporate tax disclosure?

A. Before April 3, 2008, all Ontario corporate tax disclosures were made to the Ontario Ministry of Finance. Following April 3, 2008, all Ontario corporate tax voluntary disclosures must be  made to the CRA.


Q. Where can I get more information on the new procedures and/or on how to make a corporate tax disclosure under the CRA's Voluntary Disclosures Program?

A. For information on disclosures submitted on or after April 3, 2008, or on how to make a voluntary disclosure, please contact the CRA's St. Catharines Tax Services Office by phone at 1-888-592-6869, by fax at 905-322-3133 or in writing at

Voluntary Disclosures Program

St. Catharines Tax Services Office
32 Church Street, P.O. Box 3038
St. Catharines, ON 
L2R 3B9


Q. Will the CRA be responsible for voluntary disclosures related to Ontario provincial taxes other than corporate tax?

A. The CRA is now administering disclosures for Ontario corporate tax. CRA will also continue to administer disclosures for Ontario personal income tax. Disclosures for other Ontario provincial taxes, including  Retail Sales Tax, Employer Health Tax, and Motor Fuels and Tobacco Tax will remain the responsibility of the Ontario Ministry of Finance.

For more information on making a voluntary disclosure to the Ontario Ministry of Finance, please visit their Web site at ontario.ca/finance


Q. How will I be notified of the status of my corporate tax disclosure that was made to the CRA?

A. The CRA will first acknowledge receipt of your disclosure by mail. If the CRA needs more information, you will be asked to send it to the CRA. Otherwise, you will receive a decision letter informing you whether your disclosure has been accepted or denied, and you will receive the appropriate notice regarding your assessment.


Q. Where can I find more information on the CRA's Voluntary Disclosures Program?

A. You can find more information on the CRA's Voluntary Disclosures Program on the CRA's Web site at Voluntary Disclosures Program


Section 8 – Refundable Tax Credits

Q. What tax credits are now going to be reviewed by the CRA under the Single Administration of Corporate Tax initiative?

A. Beginning on April 3, 2008, the CRA auditors are now responsible for reviewing tax credit claims for the following Ontario tax credits:

  • Ontario Innovation Tax Credit (OITC);
  • Ontario Business-Research Institute Tax Credit (OBRITC);
  • Ontario Film and Television Tax Credit (OFTTC);
  • Ontario Production Services Tax Credit (OPSTC);
  • Ontario Computer Animation and Special Effects Tax Credit (OCASETC);
  • Ontario Interactive Digital Media Tax Credit (OIDMTC);
  • Ontario Book Publishing Tax Credit (OBPTC);
  • Ontario Sound Recording Tax Credit (OSRTC);
  • Apprenticeship Training Tax Credit (ATTC);
  • Cooperative Education Tax Credit (CETC);
  • Qualifying Environmental Trust Tax Credit (QETTC).

Q. The MOF previously allowed a prepayment of up to 85% for claims filed under the following credits. Did that end with the transfer to the CRA on April 3, 2008?

  • Ontario Film and Television Tax Credit (OFTTC);
  • Ontario Production Services Tax Credit (OPSTC);

A. As of April 3, 2008, tax credit claimants file their Ontario CT23 return with the MOF for pre 2009 taxation years. Upon receipt of the completed claim, the MOF reviews the claim and where appropriate issues a partial refund (up to 85% of the amount for the OFTTC and OPSTC) within six weeks.

The MOF then notifies the CRA that the completed OFTTC or OPSTC claim is ready for CRA audit. The CRA then informs MOF of the results of the audit. MOF then sends a Notice of Assessment along with the remaining refund (if applicable) to the claimant.


Q. What do you mean by a completed claim?

A. A claim is considered complete when the Certificate of Eligibility and the Ontario CT23 return (which includes a claim for Ontario media tax credits) are filed with the MOF.


Q. Have procedures changed for filing a claim for an Ontario tax credit for pre harmonized taxation years (pre 2009 taxation years)?

A. No, there is no change in filing procedure for corporations claiming for an Ontario tax credit for 2008 or prior taxation years. As in prior years a corporation must still claim the credit on their Ontario CT23 return, and they will still receive a Notice of Assessment and refund, if applicable, from the Ontario Ministry of Finance. Please note that with a few exceptions, the CT23 Short Form Return can not be used by corporations claiming tax credits. Criteria for using the CT23 Short Form Return are included in the publication Guide to the 2007 CT23 Corporations Tax and Annual Return.

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