Search - connection

Representations made in connection with the property Gifting arrangements Appraisals for donations of gifts in kind Who has to register a tax shelter? ... Generally, a gifting arrangement is any arrangement under which it may reasonably be considered, based on statements or representations made or proposed to be made in connection with the arrangement, that a person entering into the arrangement would: make a gift to a qualified donee, or make a political contribution, of property acquired by the person under the arrangement; or incur a limited-recourse debt that can reasonably be considered to relate to a gift to a qualified donee or a political contribution. ... Representations made in connection with the property The definition of what constitutes a tax shelter depends entirely on the reasonable inferences that we can draw from representations made in connection with the property. ...

Representations made in connection with the property Gifting arrangements Appraisals for donations of gifts in kind Who has to register a tax shelter? ... Generally, a gifting arrangement is any arrangement under which it may reasonably be considered, based on statements or representations made or proposed to be made in connection with the arrangement, that a person entering into the arrangement would do one of the following: a) make a gift to a qualified donee, or make a political contribution, of property acquired by the person under the arrangement b) incur a limited-recourse debt that can reasonably be considered to relate to a gift to a qualified donee or a political contribution A political contribution refers to a monetary contribution to a registered party, a registered association, or a candidate as defined in the Canada Elections Act. ... Representations made in connection with the property The definition of what constitutes a tax shelter depends entirely on the reasonable inferences that we can draw from representations made in connection with the property. ...

Subsection 67.5(2) Non-deductibility of illegal payments- May may make such assessments, reassessments and additional assessments of tax, interest and penalties and such determinations and redeterminations as are necessary to give effect to subsection 67.5(1) Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Paragraph 70(5.2)(c) Resource property and land inventory of a deceased taxpayer- May extend the period for showing that property has become vested in the spouse, common-law partner or trust Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Subsection 70(6) Transfer or distribution of property on death- May determine a longer period that is considered reasonable in the circumstances for showing that property has become vested in a spouse, common-law partner or trust Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Subsection 70(6.1) Transfer or distribution of net income stabilization account on or after the death of a taxpayer –May determine any longer period that is considered reasonable in the circumstancesfor showing that property has become vested indefeasibly in a spouse, common-law partner or trust Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Paragraph 70(9)(c) Death of a taxpayer – May determine any longer period that is considered reasonable in the circumstances for a transfer of property to a child of the taxpayer Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Paragraph 70(9.1)(e) Death of a beneficiary- May determine any longer period that is considered reasonable in the circumstances for a transfer of property from a trust to a settlor’s child Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Paragraph 70(9.2)(c) Death of a taxpayer – May determine any longer period that is considered reasonable in the circumstances for a transfer of a family farm, fishing corporation or partnership to a child of the taxpayer Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Paragraph 70(9.3)(e) Death of a beneficiary – May determine any longer period that is considered reasonable in the circumstances for a transfer of a family farm or fishing corporations or family farm or fishing partnerships from a trust to a settlor’s child Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Paragraph 80(2)(i) May designate the order of settling of commercial obligations if the debtor does not so designate Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Subsection 80(16) May designate amounts under subsections 80(5) to (11) to the extent that the debtor would have been permitted to designate those amounts Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit Paragraph 81(4)(b) May demand an employer’s written certification in connection with an individual’s volunteer services Headquarters Positions Director General, Collections and Verification Branch Director General, Compliance Programs Branch Director, Collections and Verification Branch Director, Compliance Programs Branch Manager, Collections and Verification Branch Manager, Compliance Programs Branch Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Manager, Compliance Team Leader, Audit Team Leader, Processing/Services Team Leader, T1 Processing Team Leader, Verification History: Delegation in respect of paragraph 81(4)(b) was amended on October 19, 2020. ... Clause 139.1(2)(h)(ii)(E) May accept another day as the latest day by which a stakeholder is considered to receive a benefit in connection with a demutualization of an insurance corporation Headquarters Positions Director General, Assessment, Benefit, and Service Branch Director General, Compliance Programs Branch Director, Assessment, Benefit, and Service Branch Director, Compliance Programs Branch Manager, Assessment, Benefit, and Service Branch Manager, Compliance Programs Branch Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Audit Team Leader, Audit History: Delegation in respect of clause 139.1(2)(h)(ii)(E) was amended on November 24, 2021 and October 19, 2020. ... Subsection 241(6) May appeal an order or direction made in the course of, or in connection with, legal proceedings requiring an official or other representative of a government entity or authorized person to give or produce evidence relating to any taxpayer information Headquarters Positions Director General, Appeals Branch Director General, Charities Directorate Director General, Collections and Verification Branch Director, Collections and Verification Branch Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Chief of Appeals Manager, Appeals Manager, Litigation Team Leader, Appeals Team Leader, Litigation Subsection 241(9.3) May, in connection with a program, activity or service provided or undertaken by the Minister, make available to the public the business number and the name of the holder of a business number Headquarters Positions Director General, Assessment, Benefit, and Service Branch Director, Assessment, Benefit, and Service Branch Field Positions Director, National Verification and Collections Centre Director, Tax Centre Director, Tax Services Office Assistant Director, National Verification and Collections Centre Assistant Director, Tax Centre Assistant Director, Tax Services Office Manager, Business Returns Manager, Business Returns and Specialty Services History: Delegation in respect of subsection 241(9.3) was amended on November 24, 2021. ...

Subsection 241(6) May appeal an order or direction made in the course of or in connection with legal proceedings requiring an official or other representative of a government entity or authorized person to give or produce evidence relating to any taxpayer information Headquarters Positions Director General, Charities Directorate Director General, Collections Director General, Debt Management Compliance Director General, Tax and Charities Appeals Directorate Director, Collections Director, Non-Filer/Non-Registrant Field Positions Director, Tax Services Office Chief of Appeals Manager, Appeals Manager, Litigation History: Delegation in respect of subsection 241(6) was amended on November 6, 2014. ... Subsection 241(9.3) May, in connection with a program, activity or service provided or undertaken by the Minister, make available to the public the business number and the name of the holder of a business number Headquarters Positions Director General, Business Returns Director, Business Registration and Corporation Programs Division Field Positions Director, Tax Centre Assistant Director, Tax Centre Manager, Business Registration History: Delegation in respect of subsection 241(9.3) was amended on May 6, 2013. ... Paragraph 8502(g) Conditions applicable to all plans- May accept an arrangement under which a property is held in connection with a plan Headquarters Positions Director General, Registered Plans Directorate History: Delegation in respect of paragraph 8502(g) was amended on June 16, 2004. ...

However, there is no withholding tax on royalties or similar payments for copyright in respect of the production or reproduction of any literary, dramatic, musical or artistic work other than a motion picture film, or a film, videotape or other means of reproduction for use in connection with television (unless solely in connection with and as part of a news program produced in Canada) that has been or is to be used or reproduced in Canada. ... [Footnote 26] Royalties for the use of, or the right to use, computer software or any patent (but not including any such information provided in connection with a rental or franchise agreement) are exempt from withholding tax. ... [Footnote 37] If the beneficial owner of the royalties is a resident of this country, the following rates apply: the lower or nil rate of tax applies on the gross amount of the royalties if they are copyright royalties and other like payments in respect of the production or reproduction of any literary, dramatic, musical or artistic work (but not including royalties in respect of motion picture films nor royalties in respect of works on film or videotape or other means of reproduction for use in connection with television broadcasting), or royalties for the use of, or the right to use, computer software or any patent or for information concerning industrial, commercial or scientific experience, excluding any such information provided in connection with a rental or franchise agreement, and 10% applies on the gross amount of the royalties in all other cases, including the following: royalties in respect of motion picture films and works on film or videotape for use in connection with television broadcasting, royalties for the use of, or the right to use, any information concerning industrial, commercial or scientific experience provided in connection with a rental or franchise agreement. ...

However, there is no withholding tax on royalties or similar payments for copyright in respect of the production or reproduction of any literary, dramatic, musical or artistic work other than a motion picture film, or a film, videotape or other means of reproduction for use in connection with television (unless solely in connection with and as part of a news program produced in Canada) that has been or is to be used or reproduced in Canada. ... [Footnote 26] Royalties for the use of, or the right to use, computer software or any patent (but not including any such information provided in connection with a rental or franchise agreement) are exempt from withholding tax. ... [Footnote 37] If the beneficial owner of the royalties is a resident of this country, the following rates apply: the lower or nil rate of tax applies on the gross amount of the royalties if they are copyright royalties and other like payments in respect of the production or reproduction of any literary, dramatic, musical or artistic work (but not including royalties in respect of motion picture films nor royalties in respect of works on film or videotape or other means of reproduction for use in connection with television broadcasting), or royalties for the use of, or the right to use, computer software or any patent or for information concerning industrial, commercial or scientific experience, excluding any such information provided in connection with a rental or franchise agreement, and 10% applies on the gross amount of the royalties in all other cases, including the following: royalties in respect of motion picture films and works on film or videotape for use in connection with television broadcasting, royalties for the use of, or the right to use, any information concerning industrial, commercial or scientific experience provided in connection with a rental or franchise agreement. ...

Family connections Related persons are individuals who are related to each other by blood, marriage, common-law partnership, or adoption. ... Business connections It is generally a question of fact whether unrelated parties deal at arm’s length at any time. So it is possible that individuals not related by a family connection may still be considered not at arm’s length. ...

Family connections Related persons are individuals who are related to each other by blood, marriage, common-law partnership, or adoption. ... Business connections It is generally a question of fact whether unrelated parties deal at arm’s length at any time. So it is possible that individuals not related by a family connection may still be considered not at arm’s length. ...

Family connections Related persons are individuals who are related to each other by blood, marriage, common-law partnership, or adoption. ... Business connections It is generally a question of fact whether unrelated parties deal at arm’s length at any time. So it is possible that individuals not related by a family connection may still be considered not at arm’s length. ...

Note In April 2010, the Registered Charities Newsletter was renamed Charities Connection. ... Charities Connection No. 12- June 2012 Charities Connection No. 11- January 2012 Charities Connection No. 10- December 2011 Charities Connection No. 9- November 2011 Charities Connection No. 8- August 2011 Charities Connection No. 7- June 2011 Charities Connection No. 6- May 2011 Charities Connection No. 5- November 2010 Charities Connection No. 4- September 2010 Charities Connection No. 3- June 2010 Charities Connection No. 2- May 2010 Charities Connection No. 1- April 2010 Archive Alphabetical index Numerical index Page details Date modified: 2014-08-01 ...