UPDATED: T4As: Should we or shouldn’t we?

Staff Post
By Heather Young

According to the Canada Revenue Agency, fees for services provided by contract staff should be reported on a T4A slip in Box 048.

CRA’s Guide – titled “Filling out the T4A slip” under the Box 048 section – directs payers to: “Enter any fees or other amounts paid for services. Do not include GST/HST paid to the recipient for these services.”

A couple of observations.

The CRA makes no distinction regarding who provided the services. Many companies assume T4A slips are for freelancers – but that’s not what the Guide says. An email to the National Payroll Institute’s InfoLine as well as discussions with the CRA have confirmed that incorporated businesses should also receive T4A slips.

And for sure HST registration makes no difference! Every year, clients’ contract staff tell Young Associates bookkeepers that they don’t want a T4A slip because they have an HST number. Whether or not a contractor charges HST is irrelevant to the payer’s T-slip obligation.

Make no mistake: this has nothing to do with individual preferences. Our job is to do our best to help our clients – the payers – comply with the Income Tax Act.

We hear all sorts of variations from payers too. Some companies are willing to issue T4As to freelancers who work under their own name but not to those who have a company name. Other organizations make apparently arbitrary decisions; for instance, that they’re willing to issue T4As to actors but they don’t want to generate slips for technicians.

Indeed, there’s a lot of confusion out there – and, to boot, a tacit acknowledgement on the part of the CRA that the T4A requirement is unclear.

CRA’s Guide goes on to say: “Currently the CRA is not assessing penalties for failures relating to the completion of box 048.”

We don’t take this as a blanket pass for organizations to do whatever they want – and we don’t think you should either.

The wisdom from the National Payroll Institute – experts in the field – is that organizations should implement a process for issuing T4A slips to contractors so that when the CRA provides clear guidance they are able to comply immediately.

We can add to this some experience of payroll audits, where CRA examiners have scrutinized companies’ practices around T4A slip preparation.

Young Associates’ position is that clients need to work with their auditors and boards to interpret the Guide as best they can for their own situation. We always advocate for CRA compliance – and, if anything, for a more conservative interpretation that protects you from unwelcome attention from the government.

We appreciate comments on this post, although please note that Young Associates specializes in services for organizations. If you are an individual with a question about a T4A issue related to personal tax, we suggest that you contact a bookkeeper or accountant who prepares personal tax returns. 

Save yourself some pain: collect Tslip data and secure consent for e-distribution upon contract

One of the most painful parts of Tslip season is tracking down any missing information for recipients (e.g. SIN, address, email address) so that you can submit their tslip to the CRA and distribute their copy by the February 28 deadline. 

This can be particularly difficult with T4A recipients who are engaged on a short-term basis,  or who are living elsewhere and not in regular communication with your organization. Sometimes contract workers don’t file their income taxes on an annual basis, and therefore do not feel the same sense of urgency in regards to receiving their T4A on time… but when they’re ready to catch up, they don’t want to be delayed! 

The best way to avoid the pain is to collect all the necessary data upon engagement of the individual. Consider making full name, SIN, phone number, address, and email address standard fields on a contract, letter of agreement, or other initiating document so that you are ready for T-slip season before you pay the individual. 

And, since e-distribution of T4As, T4ANRs, and T5s (as well as certain T4s - click here for more info) requires consent from the recipient, add another standard field on your contracts to allow each individual to confirm their email address and opt in to receiving their tslip via e-distribution. 

Taking a bit of extra care at the contracting phase will save you a lot of frustration when February rolls around.  
 

Annual T-Slip Deadline – February 29, 2012

Staff Post
By Heather Young 

The annual payroll reporting deadline is looming. T4 and T4A slips must be filed by Wednesday, February 29, 2012.

T4 Slips

In preparation, you should reconcile your payroll accounts: make sure that the balance on your PD7A form (i.e. the total source deductions that the government acknowledges receiving) matches the total of the cheques you issued.

Conduct your own “pensionable and insurable earnings review.” The Canada Revenue Agency (CRA) checks this for every filer. Before you submit your T4s, you should confirm that the correct CPP and EI amounts were withheld, and were properly matched with employer contributions. If you find any shortage, it needs to be accrued to the employee record and remitted to the CRA.

Review your company’s employment relationships for any taxable benefits. Taxable benefits are items above and beyond payroll that have a value for employees, and that the CRA considers taxable income. Check this page on the CRA website for information about cell phones, parking, transit passes, insurance, gifts and other benefits.

Taxable benefits should be processed on a pay period by pay period basis, as required by law. If you’ve overlooked something, though, be sure to record it and remit the appropriate taxes at payroll year-end.

T4A Slips

Here’s the CRA’s word on when you need to issue T4A slips.

For small not-for-profits, including arts organizations, the most common requirement is to document “fees or other amounts for services.” This includes freelancer and self-employed contractor fees and, indeed, fees paid to any unincorporated business. (That is, cases where the fees are to be reported on a personal income tax return.)

Amounts paid to freelancers are to be reported on Box 48 of the T4A slip.

Here’s what the Canadian Payroll Association says about T4As: “The CRA is currently conducting a review of the types of payments that payers will be required to report in this box (i.e. Box 48). While this reporting requirement may be expanded in the future, it currently applies only to payers of independent or self-employed contractors, who should report any fees (excluding GST/HST) on the T4A using Box 48.”

Late filing

The penalties for late filing of T4 and T4A information returns can be found here on the CRA website.

Questions? Please contact us or comment below and we’ll do our best to help!