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. … "Rent-to-own" vs "sale" Policy statement P-164 … 16. … Because the self-supply rules apply only where there is a supply by way of lease, licence or similar arrangement, it is necessary to determine if a rent-to-own agreement represents a supply by way of sale or a supply by way of lease, licence or similar arrangement. ...

Frequently asked questions- Canada emergency wage subsidy (CEWS) CRA Webpage 24 September 2021-- summary under Top-Up Percentage Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Top-Up Percentage [Q.20-3] Table of top-up percentages Top-up percentage examples for claim periods 5 to 9 Top-up revenue reduction percentage Top-up percentage Top-up percentage= 1.25 x (top-up revenue reduction percentage – 50%) 70% and over 25% 1.25 x (70%- 50%) = 25% 65% 18.75% 1.25 x (65%- 50%) = 18.75% 60% 12.5% 1.25 x (60%- 50%) = 12.5% 55% 6.25% 1.25 x (55%- 50%) = 6.25% 50% and under 0.0% 1.25 x (50%- 50%) = 0% The overall wage subsidy percentage would be equal to the top-up percentage plus the base percentage. ...

Mail one completed copy of this election (plus attachments), separately from any tax return, to your tax centre by the due date identified in [Reg.] 5902(5) …. ... Surplus calculations must be filed with this election … Late or amended elections Late-filed election – subsection 93(5) – we will accept an election filed within three years after the due date and consider it to have been filed on the due date, provided an estimate of the penalty described in subsection 93(6) is paid at the time of filing the election. Special cases – subsection 93(5.1) – we may accept an election filed after the three-year due date or an amended election. ...

RC312 Reportable Transaction Information Return (2011 and later tax years)-- summary under Subsection 237.3(2) Summary Under Tax Topics- Income Tax Act- Section 237.3- Subsection 237.3(2) Part 9 – Detailed description of all the facts of the transaction and tax consequences Describe the reportable transaction in chronological order including, but not limited to, the following: the nature of the expected tax treatment and the tax consequences; a description of the tax benefit sought; the parties involved and each party's role, responsibilities and obligations; the legislative provisions that apply and how they allow the taxpayer to obtain the desired tax treatment; and any other relevant information. If the transaction is part of a series of transactions, describe each transaction in the series and identify which one is an avoidance transaction. … Part 10 – Steps and tax consequences to come Describe any remaining steps required to complete the transaction and their related tax consequences. Include the same type of information as that requested in Part 9. … Part 11 – Amount of the tax benefit or the impact on income Enter in each column the actual or estimated amount of the tax benefit resulting from the reportable transaction, or the amount of the reportable transaction's actual or estimated impact on income, for each of the periods listed in the left-hand column. ...

The payer can ask for relief on penalties and interest by writing to their tax services office or by submitting a completed Form RC4288, Request for Taxpayer Relief – Cancel or Waive Penalties or Interest. ... Collecting the appropriate forms or equivalent information will help show the payer tried to apply the correct tax rate. ¶ 21. ... (CDS) on securities registered in the name of Cede & Co. Tax on these payments is withheld by CDS based on information it receives from the Depository Trust Company (DTC) and collected by DTC participants. ...

. … The following are apportionment methods we consider to be reasonable. Liability apportionment – prorated to earnings This method apportions the liabilities based on each participating employer’s share of a member’s lifetime retirement benefits. If a member receives pensionable earnings (compensation) from multiple participating employers in the year, the actuary must use those pensionable earnings to prorate the accrued lifetime retirement benefit (LRB) and DB limit in the year. … Asset apportionment – prorated to liabilities This method apportions the assets in proportion to the liabilities allocated to each participating employer using the pensionable earnings. ...

Wilson indicated “no” – but noted that the conclusion changes if Company B does not own its own vehicles, but is acting instead as a broker. ... Scenario 6- Landscaping business sells sod Example 4 on CRA’s webpage entitled “ Tax on split income – Excluded shares ” indicated that a cleaning business that spends 15% of its revenue on cleaning products is nevertheless engaged only in cleaning services, because the supply of cleaning products is incidental to the services, whereas Example 6 found that construction materials qualified as a non-service component of a construction business. How would a landscaping business, which generates income from cutting grass, fertilizing, and sodding – which entails buying sod – be treated? ...

IT-170R "Sale of Property- When Included in Income Computation"-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition- Paragraph (e) Dispositions reference changes of beneficial ownership ¶ 4. Subparagraph 54(c)(v) [similar to what now is s. 248(1) – disposition – para. ...

Determination of partnership status of foreign partnership by reference to provincial law 20. … Continental Bank … Backman … and Spire Freezers confirmed that the existence of a partnership must be determined by reference to the relevant partnership law of the province or territory and this is the case even when dealing with a partnership established in a jurisdiction outside Canada. ... In addition, express declarations against the existence of a partnership will not be determinative if the facts indicate otherwise. … 31. ... A partnership is distinguished from … other types of relationships and arrangements [which] include joint ventures, co-ownership relationships, and fee-sharing and cost-sharing arrangements. … Whether a partner in a foreign limited partnership need contribute capital 74. … [L]egislation in certain jurisdictions of other countries may permit the formation of a partnership having a legal personality distinct from its members, with limited liability for debts and obligations afforded to all members, including the general partner. ...

Based on the average retail price per meal at the university, the single amount paid by a student is sufficient to provide the student with at least 10 meals each week for the period of the plan ($7.25 × 10 meals × 34 weeks = $2,465). ...