Compliance Headaches –
T4A Information Slip – The confusion of Box 048
While January does not guarantee snow, it marks the beginning of the busiest season for most accountants, especially tax accountants… the preparation of the various information slips (T4, T4A, T5 etc), trust returns, and of course personal tax returns.
To make things more complicated, Canada Revenue Agency (CRA) redesigned the T4A slip last year and introduced new Box 048 – “fees paid for services”.
By way of background, a T4A slip is traditionally used to report income exceeding $500 that does not fit into other T-slips, or when income tax has been withheld. For example, pension, self-employed commissions, annuities, RESP payments and scholarships are to be reported on T4A slips.
However, the description provided by CRA regarding the new Box 048 is troublesome.
“Any person who makes a payment for fees for services should report these amounts in box 048 of the T4A slip. Payers of these fees are responsible for providing copies of this slip to both the recipient and the CRA.”
Being a “person” myself, I pay for all sorts of fees for services on a daily basis – dental, hair salon, cleaning, cab, service charges at restaurants etc. Does this mean I am now responsible for issuing T4A slips to all these people when the amount is over $500? From a business perspective, does this Box 048 requirement apply to the legal bills, courier, and web services?
To ease (postpone?) the pain in compliance, CRA made the following announcement on its website (http://www.cra-arc.gc.ca/tx/bsnss/tpcs/pyrll/rtrns/t4a/slps/cmpltng/bx48-eng.html) as of December 16, 2011:
Until such time as the CRA undertakes a review for the purposes of clarifying the types of fees for services that are to be reported on the T4A slip, taxpayers will not be penalized for failing to complete Box 048.
In the meantime, all fees for services that were previously reported in Box 28 on the original version of the T4A slip should continue to be reported on the redesigned T4A slip.
We will need to revisit this issue next year, I guess.
