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GST/HST Interpretation
17 June 2024 GST/HST Interpretation 203070 - Application to Bitcoin Mining and the Sale of Bitcoins
A ”mining activity” is defined in subsection 188.2(1) to mean “an activity of (a) validating transactions in respect of a cryptoasset and adding them to a publicly distributed ledger on which the cryptoasset exists at a digital address; (b) maintaining and permitting access to a publicly distributed ledger on which a cryptoasset exists at a digital address; or (c) allowing computing resources to be used for the purpose of, or in connection with, performing activities described in paragraph (a) or (b) in respect of a cryptoasset.” ... Subject to the exclusion in subsection 188.2(5), per subsection 188.2(2), to the extent that a person acquires, imports or brings into a participating province, property or a service for consumption, use or supply in the course of, or in connection with, mining activities of the person, the person is deemed to have acquired, imported or brought into the participating province, as the case may be, the property or service for consumption, use or supply otherwise than in the course of commercial activities of the person. ... In addition, if a person at any time consumes, uses or supplies property or a service in the course of, or in connection with, mining activities of the person, that consumption, use or supply is deemed to be otherwise than in the course of commercial activities of the person per subsection 188.2(3), if the consumption, use or supply of the property or service occurs after February 4, 2022. ...
Old website (cra-arc.gc.ca)
Guidance on the Common Reporting Standard
The same applies in connection with any client trust account held by a lawyer in trust for a single client in connection with legal services if the above-referenced conditions are satisfied and the lawyer's actions in connection with the opening, use and management of the account are regulated by a law society in Canada. ... If the account holder has either status, reporting obligations to the CRA will exist in connection with the account. ... Account information 12.7 Financial institutions must report account information in connection with the reportable account. ...
Old website (cra-arc.gc.ca)
Chapter History: S1-F2-C1, Education and Textbook Tax Credits
However, these sections now appear in the Table of contents for easy access; the statement that folios are only available in electronic format has been moved to the end of the Application section; and the words “as promulgated under the Act” in connection with the Income Tax Regulations have been removed from the Application section, in the interest of using plain language. ... These references are made in connection with the certification of an educational institution in Canada which provides courses, other than courses designed for university credit, that furnish a person with skills for, or improve a person’s skills in, an occupation. ... Pursuant to this amendment, programs taken by students in connection with, or as part of, their duties of an office or employment are not excluded from the definition of a qualifying educational program for 2004 and subsequent tax years. ...
Archived CRA website
ARCHIVED - Damages, Settlements and Similar Payments
If damages are incurred in connection with the acquisition of an asset for which capital cost allowance may be claimed, the cost of the damages is included in the capital cost of that asset (or the CCA class to which the asset belongs). ... If damages are incurred in connection with the acquisition or production of inventory, the cost of the damages is included in the cost of inventory. If damages are incurred in connection with the disposition of a capital property, the cost of the damages is taken into account under subsection 40(1) for the purposes of calculating any gain or loss on that disposition. ...
Old website (cra-arc.gc.ca)
Meaning of the First Part of the Definition of Busines
This profit test does not apply to the making of a supply of real property (other than an exempt supply), including anything done in the course of or in connection with the making of the supply, which is a commercial activity by virtue of paragraph (c) of the definition. ... Given the reference to whether an undertaking is engaged in for profit, it is the CCRA's position that "undertaking" is restricted to those activities that have some connection or similarity to an undertaking that would be carried out with profit as its objective. ... However, such an undertaking would have to be carried on in a "business-like" manner, having some connection or similarity to an undertaking that would be carried out with profit as its objective. ...
Old website (cra-arc.gc.ca)
Chapter History: S1-F2-C3, Scholarships, Research Grants and Other Education Assistance
However, these sections now appear in the Table of contents for easy access; the statement that folios are only available in electronic format has been moved to the end of the Application section; and the words “as promulgated under the Act” in connection with the Income Tax Regulations have been removed from the Application section, in the interest of using plain language. ... Subparagraph 56(1)(r)(v) was added by 2009, c. 2, s. 13(2), applicable to the 2008 and subsequent tax years. ¶3.81 has been added to describe the taxation of certain assistance received by an individual in connection with their participation in an employment-related activity, in line with various CRA interpretations on the subject matter. ¶3.84- 3.85 have been added to note that certain payments may be considered social assistance under paragraph 56(1)(u) or a scholarship or bursary under paragraph 56(1)(n) depending on its primary purpose, in line with CRA interpretations and jurisprudence. ¶3.87 (formerly ¶41 of IT-75R4) has been revised to reflect the amendment to Article XX of the Convention between Canada and the United States of America with Respect to Taxes on Income and on Capital pursuant to the coming into force of the Fifth Protocol. ... This amendment was made by 2007, c. 2, s. 6(3), effective for the 2006 and subsequent tax years, to increase the $3,000 exemption to an unlimited exemption where scholarship income was received in connection with an educational program that qualified under subsection 118.6(2). ¶3.91 (formerly included in ¶43 of IT-75R4) has been revised to reflect the amendment to paragraph 56(3)(a) to effectively extend (i) to the preceding and following years. ...
Current CRA website
Chapter History
However, these sections now appear in the Table of contents for easy access; the statement that folios are only available in electronic format has been moved to the end of the Application section; and the words “as promulgated under the Act” in connection with the Income Tax Regulations have been removed from the Application section, in the interest of using plain language. ... Subparagraph 56(1)(r)(v) was added by 2009, c. 2, s. 13(2), applicable to the 2008 and subsequent tax years. ¶3.81 has been added to describe the taxation of certain assistance received by an individual in connection with their participation in an employment-related activity, in line with various CRA interpretations on the subject matter. ¶3.84- 3.85 have been added to note that certain payments may be considered social assistance under paragraph 56(1)(u) or a scholarship or bursary under paragraph 56(1)(n) depending on its primary purpose, in line with CRA interpretations and jurisprudence. ¶3.87 (formerly ¶41 of IT-75R4) has been revised to reflect the amendment to Article XX of the Convention between Canada and the United States of America with Respect to Taxes on Income and on Capital pursuant to the coming into force of the Fifth Protocol. ... This amendment was made by 2007, c. 2, s. 6(3), effective for the 2006 and subsequent tax years, to increase the $3,000 exemption to an unlimited exemption where scholarship income was received in connection with an educational program that qualified under subsection 118.6(2). ¶3.91 (formerly included in ¶43 of IT-75R4) has been revised to reflect the amendment to paragraph 56(3)(a) to effectively extend (i) to the preceding and following years. ...
Current CRA website
Meaning of the First Part of the Definition of Business
This profit test does not apply to the making of a supply of real property (other than an exempt supply), including anything done in the course of or in connection with the making of the supply, which is a commercial activity by virtue of paragraph (c) of the definition. ... Given the reference to whether an undertaking is engaged in for profit, it is the CCRA's position that "undertaking" is restricted to those activities that have some connection or similarity to an undertaking that would be carried out with profit as its objective. ... However, such an undertaking would have to be carried on in a "business-like" manner, having some connection or similarity to an undertaking that would be carried out with profit as its objective. ...
Scraped CRA Website
Chapter History
However, these sections now appear in the Table of contents for easy access; the statement that folios are only available in electronic format has been moved to the end of the Application section; and the words “as promulgated under the Act” in connection with the Income Tax Regulations have been removed from the Application section, in the interest of using plain language. ... These references are made in connection with the certification of an educational institution in Canada which provides courses, other than courses designed for university credit, that furnish a person with skills for, or improve a person’s skills in, an occupation. ... Pursuant to this amendment, programs taken by students in connection with, or as part of, their duties of an office or employment are not excluded from the definition of a qualifying educational program for 2004 and subsequent tax years. ...
Current CRA website
Meaning of the First Part of the Definition of Business
This profit test does not apply to the making of a supply of real property (other than an exempt supply), including anything done in the course of or in connection with the making of the supply, which is a commercial activity by virtue of paragraph (c) of the definition. ... Given the reference to whether an undertaking is engaged in for profit, it is the CCRA's position that "undertaking" is restricted to those activities that have some connection or similarity to an undertaking that would be carried out with profit as its objective. ... However, such an undertaking would have to be carried on in a "business-like" manner, having some connection or similarity to an undertaking that would be carried out with profit as its objective. ...