Hello to the Listserv - 

Apologies if this has been asked before, but my searches on the listserv came 
up blank.

My company is thinking of migrating first their email and then data (over the 
next 5-7 years) to the cloud.  Understanding that most cloud servers are 
housed in the United States, and that we are a Canadian company, I have 
reservations.

In the most recent CRA circular that I could find on electronic record keeping 
(IC05-1R1 - June 2010), the wording on where electronic/paper records need 
to be housed is unclear.  

Location of Records

9.  ...Records kept outside Canada and accessed electronically from Canada 
are not considered to be records in Canada.  However, where records are 
maintained electronically in a location outside of Canada, the CRA may accept 
a copy of the records, provided these are made available in Canada in an 
electronically readable and useable format....

10.  All retained records must be clearly labelled and stored in a secure 
environment in Canada.

In X6.1 Books and Records (Oct 2013), it states:

26.  All retained electronic records must be clearly labelled and stored in a 
secure environment in Canada. Permission to store retained electronic records 
elsewhere may be granted to persons whose accounting systems are 
centralized outside Canada. The authorization may be obtained by writing to 
your nearest CRA tax services office. It is highly recommended that back-up 
electronic records that are retained for the CRA be stored at an off-site 
location.

So I'm faced with a company eager to move their documents to the cloud, 
but with a regulatory agency that appears to say they can't unless the cloud 
is based in Canada.

Is my conclusion correct, or am I missing something?  

Thanks in advance to all of you.

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