CRA e-services – Key updates for tax practitioners

As the CRA continues to enhance its online processes for interacting with taxpayers and practitioners, we’ve rounded up some of the most important changes and summarized them in this blog. 

Key topics are:

• Confirm my Representative – concerns
• Represent a Client – authorization signature page 
• Progress tracker – self-service updates for filings in progress
• Change My Return and ReFile – recent enhancements
• Special elections and returns – electronic filing options
• My Trust Account – initial services launched

CONFIRM MY REPRESENTATIVE – CONCERNS

The CRA has changed its process for businesses wanting to authorize a new representative for access to the business’ tax information in the Represent a Client (RAC) portal. Under the Confirm my Representative process, representatives who use certified tax software (EFILE) for authorization requests must have the business owner confirm the request in My Business account within 10 business days. This requirement also applies to authorization requests made through RAC.

Since the new requirement took effect for e-filed requests in fall 2022, members have contacted us with significant concerns. Among other issues, members told us:

• Many of their clients do not use My Business Account (MyBA), and those who don’t face logistical issues accessing the system.
• Non-residents may be unable to access MyBA, so the CRA may call the business owner to confirm the authorization request, causing more issues.
• For large businesses, the authorization requests may have to be confirmed by directors or other senior officials and having these individuals confirm representative changes online has proven to be difficult.

We have raised these concerns with the CRA, and our discussions continue. We are also developing guidance on how to deal with some of the issues that might arise, including details on how to update ownership information in MyBA in various scenarios such as when incorporating a new corporation or when an existing business transfers to new owners.

Note that this authorization process will also be followed to Confirm Representative access to the CRA’s new My Trust Account service using RAC.

However, the CRA confirmed that the authorization process will not change for requests made on behalf of individual taxpayers. In particular, Confirm my Representative does not have to be used for authorization requests for individuals that are e-filed.

REPRESENT A CLIENT – AUTHORIZATION SIGNATURE PAGE

Now that the new Confirm my Representative process is in place, the CRA says signature pages are no longer generated for authorization requests submitted in RAC for individual accounts where the My Account option is selected as the confirmation method. If an authorization request was initiated before February 6, 2023, the signature page that was generated does not have to be completed to get access after that date.

For other services, such as business accounts, the generated signature page is still required despite the new process. We have asked the CRA to remove the signature page requirement in these circumstances as well and will update you on future developments.

PROGRESS TRACKER – SELF-SERVICE UPDATES FOR FILINGS IN PROGRESS

The CRA’s digital Progress Tracker service gives taxpayers a self-serve option to track the status of files submitted through the CRA’s secure portals. Since the service launched early in 2022, the CRA has expanded its scope to track more types of filings.

In My Account, as of February 2023, taxpayers and representatives can use Progress Tracker to monitor the status of:

• Disability Tax Credit claims (however, the CRA has stated that submissions made between February 6 and May 14, 2023, will not be tracked due to a system upgrade)
• taxpayer relief requests
• notices of objection
• T1 returns and reassessments
• Canada Child Benefit claims

In My Business Account, you can currently track:

• charity registration applications
• Registered Charity Information Returns (T3010)
• notices of objection
• T2 returns and adjustments

We understand that the CRA will continue adding more programs and forms to the Progress Tracker in the future.

CHANGE MY RETURN AND REFILE – RECENT ENHANCEMENTS

The CRA will enhance its two online service options for changing T1 tax returns: Change my return (CMR), which is accessed through My Account and RAC, and ReFILE, which enables T1 adjustments to be submitted through certified tax filing software. According to information we received from the CRA, some of the key changes to these services are as follows (the CRA website had not been updated at the time of writing):

• New CMR Interfaces – CMR will have a Disability Tax Credit (DTC) calculation interface that enables users to easily add DTC claims to a taxpayer’s return. This interface is only displayed for taxpayers who are already approved for the DTC.
  
  Also added will be an Information Slip interface that enables users to add T4 and other information slips to a tax return. Users can select individual slips to be added or they can choose to add all information slips that the CRA has on file for that taxpayer for the selected tax year.
• CMR and ReFILE restrictions eased – Some restrictions in CMR and ReFILE will be lifted to allow both services to accept adjustments related to Form T1A, Request for Loss Carryback and Form T1032, Joint Election to Split Pension Income. The systems also now allow more than one reassessment to be in progress at the same time.
• International and non-resident taxpayers – Some international and non-resident taxpayers will be able to submit requests to change their returns using the CMR service. The CRA has indicated that it will post a complete list of the eligible return types on its website.
• Factual assessments – Taxpayers who have received assessments under subsection 152(7) of the Income Tax Act, also known as factual assessments, will be able to file their returns electronically in response to these assessments using tax filing software. Until recently, only paper-filed returns were accepted.
• Submitting supporting documents – When a request to change a return is submitted via CMR or ReFILE that requires supporting documents, a letter will be issued through My Account or mail (based on the taxpayer’s communication preference) providing details about the documents required and the timeframe for submitting them. Documents can be uploaded electronically using Submit Documents within MyAccount, and they will be automatically routed to the appropriate program for processing.

We hear from taxpayers and tax preparers that they would prefer to send in all supporting documentation when they file the adjustment. The inability to do so is one of the main reasons many of them continue filing T1 adjustments by paper. We have passed this feedback along to the CRA.

SPECIAL ELECTIONS AND RETURNS – ELECTRONIC FILING OPTIONS

Special elections and returns (SERS) are filed voluntarily by taxpayers to qualify for certain tax provisions, such as Form T2054 for making capital dividend elections. The CRA has posted a list of all SERS on its website.

In late 2022, the CRA launched new filing options for SERS. Currently, the CRA’s SERS page indicates that you can file these elections and returns electronically using My Account, My Business Account or Represent a Client. 

We understand from the CRA that the ability to EFILE certain SERS will become available in certified tax software later this year.

Below are some key questions we asked the CRA about the new SERS electronic filing process and the CRA’s responses.

Question 1: When a SERS is submitted, will a receipt be provided that can be printed off as proof of filing and/or will My Business Account or RAC allow the user to see that the form has been filed? Will the receipt or webpage update specify what form was filed?

CRA response: A confirmation number and reference number is provided for every document successfully submitted via the Submit Documents online service. A screen print of the confirmation page could be used as proof of filing. Currently, the Submit docs confirmation page does not refer to which form was submitted; however, the name of the file is displayed on the confirmation page.

Question 2: We understand that no electronic signatures are acceptable for CRA forms, except for forms T183 and T2200. For all other SERS submitted online, this means representatives should:

• print the completed form and have the client manually sign it
• submit a scan of the signed form
• have the taxpayer keep a copy (or the representative should retain a copy if the SERS was filed through RAC)

Can the CRA confirm that this is the process that should be undertaken for SERS filed electronically?  

CRA response: This is correct. The website will be updated accordingly to reiterate this policy for documents filed using the Submit Documents online service.

Question 3: For forms such as T2054 and Schedule 89, we assume specific groups within the CRA will receive the file since they are specifically identified on the CRA’s drop down list. For other SERS included in the service, will the CRA implement a process to ensure each type of SERS goes to the right CRA department?

CRA response: Yes, a mechanism in place to ensure all forms listed on the website are appropriately routed. 

MY TRUST ACCOUNT – INITIAL SERVICES LAUNCHED

The CRA announced that it has implemented an initial set of services in My Trust Account allowing legal and authorized representatives of trusts to view and manage trust information online.

My Trust Account can be accessed through RAC. Trust clients have been added as a new client type to RAC. Authorized representatives can now access trust client accounts in the same way they access individual and business client accounts.

The CRA acknowledges that the initial services available in My Trust Account are limited but indicates these services will expand in the future.

Note also that a primary trustee must first register as such in RAC before they can access My Trust Account. After being confirmed as the primary trustee of the trust account, the trustee will have access and the ability to add additional trustees or authorized representatives.

WE’LL KEEP YOU POSTED

For more information on the above and other tax topics as things develop, be sure to check our Canadian tax news webpage regularly for updates.