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TCC (summary)

Mac & Mac Hydrodemolition v. The Queen, 2017 TCC 256 (Informal Procedure) -- summary under Scientific Research & Experimental Development

In denying the taxpayer’s SR&ED claims, Graham J stated (at paras 7, 8, 9 and 10): Mac & Mac’s claims do not meet the last test [in Northwest Hydraulic.] ... Mac & Mac kept a set of handwritten notes. There is simply no way that someone, even someone very experienced in the industry, could hope to replicate or confirm Mac & Mac’s results from these notes. A spreadsheet provided more detail than the notes. However, it was prepared after the fact for the purpose of supporting the SR&ED claim and still did not contain the level of detail I would have expected. As noted in Highweb & Page Group Inc. v. ...
SCC

Town of Beauport v. Quebec Railway, Light & Power Co. / Quebec Railway, Light & Power Co. v. Town of Beauport, [1945] SCR 16

Quebec Railway, Light & Power Co. / Quebec Railway, Light & Power Co. v. ... Upon the declaration being made that the works of the Company were for the general advantage of Canada, the effect of subsection 10 of s. 92 of The British North America Act is * * * to transfer the * * * works mentioned * * * into s. 91 and thus to place them under the exclusive jurisdiction and control of the Dominion Parliament. ...
GST/HST Interpretation

15 May 2014 GST/HST Interpretation 155042 - – […] [FCTIP – Foreign Convention]

Individual participants chose […] for the […] portion of [the Event]. […]. 15. […] 16. The schedule for [the Event] […] [was] as follows: […] 17. [The Event] was officially opened […]. ... The […] portion of [the Event] provided participants with the opportunity to […] while discovering […][a Canadian City] through […] activities. […]. 24. […] 25. ...
Administrative Policy summary

GST/HST Audit and Examination Manual, 9 – Taxpayer Rights and Taxpayer Relief – 9.1.6.3 “ The right to privacy and confidentiality -- summary under Subsection 295(5)

GST/HST Audit and Examination Manual, 9 Taxpayer Rights and Taxpayer Relief 9.1.6.3 The right to privacy and confidentiality-- summary under Subsection 295(5) Summary Under Tax Topics- Excise Tax Act- Section 295- Subsection 295(5) Informal request in lieu of ATIP request When an access to information and privacy (ATIP) request is received, the Access to Information and Privacy Directorate of the Public Affairs Branch forwards the request to the appropriate party(ies) to obtain the relevant information. ... Permitted scope of informal request Some examples of information that can be released to a registrant or authorized representative under an informal request include: the T20 Report external and internal correspondence, including memoranda, appropriately severed where necessary related correspondence with Headquarters such as technical interpretation requests or opinions and referrals to specialized sections about a specific person working papers, excluding third-party information, leads, disclosure of audit techniques, and information from informants related reports from external and internal valuators, appraisers and electronic commerce audit specialists, severed versions of operations manuals available to the public Examine the documents before releasing them to ensure no confidential information about a third party is released. Prohibited disclosures Examples of information that cannot be released are: information obtained in confidence during an audit or examination that may prejudice the results of the audit or examination, such as Criminal Investigation reports, Royal Canadian Mounted Police reports, or documents obtained as part of an investigation audit techniques and specific audit guidelines information about investigations in process when a decision is pending documents of a related file under investigation confidential information about another registrant Department of Justice correspondence and information under solicitor-client privilege, including legal opinions from the Legal Services Branch (for more information, go to Disclosing legal opinions and Use of legal opinions inside the Agency) specific advice and recommendations developed by or for a government institution or minister of the Crown that may restrict the CRA's ability to administer the ETA if they are disclosed accounts of consultations and deliberations involving officials or employees of a government institution or a minister of the Crown that may reasonably be expected to cause injury or restrict the CRA's ability to administer the ETA if disclosed information released to a third party, other than specifically permitted by paragraph 295(5)(d) of the ETA or where consent is given by the registrant copyright material computer printouts from CRA computer systems. ...
Current CRA website

Chapter 15 - 8507 & 8508 – Periods of Reduced Pay & Salary Deferral Leave Plan

Chapter 15- 8507 & 8508 Periods of Reduced Pay & Salary Deferral Leave Plan On this page... 15 8507 & 8508 Periods of Reduced Pay & Salary Deferral Leave Plan 15.1 8507(1) Prescribed Compensation 15.2 8507(2) Additional Compensation in Respect of Qualifying Period 15.3 8507(3) Qualifying Periods and Periods of Parenting 15.3.1 8507(3)(a) Qualifying period 15.3.2 8507(3)(b) Period of parenting 15.4 8507(4) Cumulative Additional Compensation Fraction 15.5 8507(5) Additional Compensation Fraction 15.6 8507(6) Exclusion of Subperiods 15.7 8507(7) Complete Period of Reduced Pay 15.8 8508 Salary Deferral Leave Plan 15 8507 & 8508 Periods of Reduced Pay & Salary Deferral Leave Plan Section 8507 of the Regulations contains rules that enable DB benefits to be provided, or MP contributions to be made, in respect of a period of disability, a leave of absence, or a period of reduced pay as if it were a regular period of employment without violating the PA limits in subsections 147.1(8) and (9) of the Act. ... Cross references: Pension Adjustment Limits 147.1(8) Pension Adjustment Limits Multi-Employer Plans 147.1(9) Period of Reduced Services Retroactive Benefits 8308(4) Period of Reduced Services Retroactive Contributions 8308(5) Definition of Eligible Periods of Reduced Pay 8500(1) Definition of Eligible Periods of Temporary Absence 8500(1) Definition of Periods of Disability 8500(1) Additional Compensation in Respect of Qualifying Period 8507(2) Qualifying Periods 8507(3) 15.2 8507(2) Additional Compensation in Respect of Qualifying Period This subsection contains the rules for determining the amount that is prescribed by subsection 8507(1) of the Regulations in respect of a qualifying period of a member in a year with respect to an employer. ... Cross references: Definition of Eligible Periods of Reduced Pay 8500(1) Definition of Eligible Periods of Temporary Absence 8500(1) Deemed Allocation of Forfeitures and Surplus 8500(7) Definition of SMEP 8510(2) 15.3.2 8507(3)(b) Period of parenting This is all or part of the period that starts at the time of the birth or adoption of a child and ends 12 months later. ...
Technical Interpretation - Internal summary

7 May 1995 Internal T.I. 9510220 - PART I.3, O/S CHEQUES & OVERDRAFTS -- summary under Payment & Receipt

7 May 1995 Internal T.I. 9510220- PART I.3, O/S CHEQUES & OVERDRAFTS-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt conditional payment principle accepted Bank overdrafts are considered to have arisen to the extent that they have been utilized or drawn upon. ...
Current CRA website

Chapter 6 - 8303, 8308 & 8409 – Pension Adjustments & Annual Information Returns

Chapter 6- 8303, 8308 & 8409 Pension Adjustments & Annual Information Returns 6.1 8303(6) Qualifying Transfers 6.2 8303(7) Deemed Payment 6.3 8303(10) Benefits in Respect of Foreign Service 6.4 8308(7) Loaned Employees 6.5 8409(1) and (2) Annual Information Returns 6.1 8303(6) Qualifying Transfers Subsection 8303(6) of the Regulations defines for the purposes of the description of C in the formula in subsection 8303(3) (basic PSPA calculation), the description of D in the formula in subsection 8304(5) (modified PSPA calculation) and the description of B in the formula in subsection 8304(10) (IPP PSPA calculation), the amount of an individual’s qualifying transfer made in connection with a past service event. ... Cross reference: Deemed Registration 147.1(3) 6.3 8303(10) Benefits in Respect of Foreign Service Subsection 8303(10) of the Regulations allows the CRA to exclude past service benefits provided for a period of foreign service from PSPAs. ... Cross references: Participating Employer 147.1(1) Pension adjustment limits 147.1(8), 147.1(9) Eligible Service 8503(3)(a) Maximum Benefits 8504(1) Additional Compensation Fraction 8507(5) 6.5 8409(1) and (2) Annual Information Returns The plan administrator will have to file either: a joint annual information return by the date prescribed under the pension benefits legislation of a participating provincial pension supervisory authority; or for a non-participating pension supervisory authority a Form T244, Registered Pension Plan Annual Information Return, within 180 days of the plan's year-end. ...

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