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GST/HST Interpretation
19 May 2011 GST/HST Interpretation 131970 - GST/HST INTERPRETATION - Application of the GST/HST to Look-See Fees and Completion Fees
Co owns all rights, title and interests, including intellectual property rights in and to: (a) the Portals, including all content thereat, excluding any content provided by the Lenders to X Co. for use in connection with the Supply; (b) any domain names registered by X Co. in connection with the Portals and/or the Supply; (c) all trademarks, logos or other identifying names or marks used in connection with the Portals, except for the trademarks and logos owned by the Lenders; (d) the Software and all associated documentation, including training and user documentation provided by X Co. for use in connection with the Supply and the business model related to the provision of the Supply; and (e) any interface, including data maps, constructed in order for the Portals to access the Lenders' computer systems. ...
Current CRA website
How we combat tax evasion and avoidance
Through this process, the CRA identified over 900 individuals, corporations, and trusts with a potential connection to Canada. ... Since the release of the Paradise Papers, the CRA has reviewed all the taxpayers identified with a potential connection to Canada. The CRA identified approximately 2,790 individuals, corporations, and trusts with a potential connection to Canada. ...
Current CRA website
2011 Budget - Questions and answers
An advantage in relation to an RRSP or RRIF is any benefit, loan or debt that depends on the existence of the RRSP or RRIF, other than distributions, administrative or investment services in connection with the RRSP or RRIF, loans on arm's length terms, and payments or allocations (such as bonus interest) to the RRSP or RRIF by the issuer or carrier. ... An advantage also includes an RRSP strip or any benefit that is income (including a capital gain) that is reasonably attributable, directly or indirectly, to a prohibited investment in respect of the RRSP or RRIF or any other RRSP or RRIF of the annuitant; or an amount received by the annuitant of the RRSP or RRIF (or by a person not dealing at arm's length with the annuitant) if it is reasonable to consider that the amount was paid in relation to, or would not have been paid but for, property held in connection with the RRSP or RRIF, and the amount was paid in substitution for either a payment for services provided by the annuitant (or another person not at arm's length with the annuitant); or of a return on investment or proceeds of disposition. ... Similarly, financial institutions are required to determine the fair market value of property held in connection with RRIFs for purposes of determining annual minimum amount payments. ...
Current CRA website
Guidelines for Taxpayers Requesting Treaty Benefits Pursuant to Paragraph 6 of Article XXIX A of the Canada-U.S. Tax Convention
After submitting a Request, you must inform Competent Authority of any material change in the information or documentation previously submitted as part of, or in connection with, the Request, as well as new information or documentation relevant to the issues under consideration. ... Organizational A description with appropriate organizational charts that describe the taxpayer's chain of ownership to its ultimate owner(s) and its control over or connections with any related or unrelated entity from which income covered by this request was, or can be expected to be received. ... Statement whether an audit or review by any tax authority has been or is currently in progress that relates to the relief request and a statement on whether any assessment has been issued by any tax administration in connection with the income in respect of which benefits are sought. ...
Current CRA website
Tax-Free Savings Accounts
After the death of the individual, the surviving spouse or common-law partner (here referred to as the survivor) can become the successor holder if the survivor acquires all of the individual’s rights as holder of the arrangement including the unconditional right to revoke any beneficiary designation made (or similar direction imposed) by the individual under the arrangement or relating to property held in connection with the arrangement. ... In addition, the specimen must comply with subsection 146.2(2) of the ITA by including the following provisions: 146.2(2)(a) – The arrangement requires that it be maintained for the exclusive benefit of the holder. 146.2(2)(b) – The arrangement prohibits, while there is a holder of the arrangement, anyone that is neither the holder nor the issuer of the arrangement from having rights under the arrangement relating to the amount and timing of distributions and the investing of funds. 146.2(2)(c) – The arrangement prohibits anyone other than the holder from making contributions under the arrangement. 146.2(2)(d) – The arrangement permits distributions to be made to reduce the amount of tax otherwise payable by the holder under section 207.02 or 207.03 of the ITA. 146.2(2)(e) – The arrangement provides that, at the direction of the holder, the issuer shall transfer all or any part of the property held in connection with the arrangement (or an amount equal to its value) to another TFSA of the holder. 146.2(2)(f) – If the arrangement is an arrangement in trust, it prohibits the trust from borrowing money or other property for the purposes of the arrangement. 146.2(2)(g) – The arrangement complies with prescribed conditions. ... The issuer may also want to include on the application form: a statement that the holder must notify the issuer when they are not resident in Canada; a warning to the holder that they may be liable for certain tax consequences arising in connection with a non-compliant qualifying arrangement; and a space where the holder can indicate whether, in the event of their death, the holder’s survivor (with space for the spouse’s or common-law partner’s name and social insurance number) acquires all of their rights as the holder of the arrangement, and the unconditional right to revoke any beneficiary designation made, or similar direction imposed, by the individual under the arrangement or relating to property held in connection with the arrangement. ¶ 18. ...
Current CRA website
How to purchase an advanced life deferred annuity (ALDA)
This is the excess ALDA transfer. 2024-04-15 RRIF A00000001 90,000 200,000 0 200,000 50,000 0 50,000 40,000 2024-04-16 RRIF B00000002 80,000 100,000 0 100,000 25,000 0 25,000 55,000 ** Do not include the following amounts when calculating the fair market value (FMV) of your account in the plan: If the transfer is from a registered pension plan (RPP): property held in connection with a defined benefit provision of the RPP, or a variable payment life annuity (VPLA) fund of the RPP. ... This is the excess ALDA transfer. 2024-04-15 MP RPP A00000001 125,000 500,000 0 500,000 125,000 0 125,000 0 2024-06-16 RRIF B00000002 70,000 280,000 0 280,000 70,000 0 70,000 0 ** Do not include the following amounts when calculating the fair market value (FMV) of your account in the plan: If the transfer is from a registered pension plan (RPP): property held in connection with a defined benefit provision of the RPP, or a variable payment life annuity (VPLA) fund of the RPP. ... This is the excess ALDA transfer. 2024-04-15 RRIF A00000001 70,000 280,000 0 280,000 70,000 0 70,000 0 2024-04-16 RRIF B00000002 35,000 140,000 0 140,000 35,000 0 35,000 0 2024-07-20 RRIF A00000001 15,000 280,000 0 280,000 70,000 70,000 0 15,000 2024-08-03 RPP RPP0000003 60,000 500,000 0 500,000 125,000 0 125,000 0 ** Do not include the following amounts when calculating the fair market value (FMV) of your account in the plan: If the transfer is from a registered pension plan (RPP): property held in connection with a defined benefit provision of the RPP, or a variable payment life annuity (VPLA) fund of the RPP. ...
Old website (cra-arc.gc.ca)
Ontario and British Columbia: Transition to the Harmonized Sales Tax - Prepaid Funeral and Cemetery Arrangements and Interment Property
It includes property and services such as those provided for the care and embalming of the deceased individual or in connection with the funeral rite of the deceased individual, and the transportation of the deceased individual. ... For details on how to determine whether GST or HST applies to services (other than funeral or cemetery services) supplied in connection with a prepaid arrangement, see the information under the heading "Other services. ... Other services Some operators charge fees for other services that are not funeral or cemetery services, but are supplied in connection with prepaid arrangements. ...
Old website (cra-arc.gc.ca)
Prince Edward Island: Transition to the Harmonized Sales Tax Prepaid Funeral and Cemetery Arrangements and Interment Property
It includes property and services such as those provided for the care and embalming of the deceased individual or in connection with the funeral rite of the deceased individual, and the transportation of the deceased individual. ... For details on how to determine whether GST or HST would apply to services other than funeral or cemetery services supplied in connection with a prepaid arrangement, refer to "Other services. ... Other services Some operators charge fees for other services that are not funeral or cemetery services, but that are supplied in connection with prepaid arrangements. ...
Current CRA website
Ontario and British Columbia: Transition to the Harmonized Sales Tax - Prepaid Funeral and Cemetery Arrangements and Interment Property
It includes property and services such as those provided for the care and embalming of the deceased individual or in connection with the funeral rite of the deceased individual, and the transportation of the deceased individual. ... For details on how to determine whether GST or HST applies to services (other than funeral or cemetery services) supplied in connection with a prepaid arrangement, see the information under the heading "Other services. ... Other services Some operators charge fees for other services that are not funeral or cemetery services, but are supplied in connection with prepaid arrangements. ...
Current CRA website
Prince Edward Island: Transition to the Harmonized Sales Tax – Prepaid Funeral and Cemetery Arrangements and Interment Property
It includes property and services such as those provided for the care and embalming of the deceased individual or in connection with the funeral rite of the deceased individual, and the transportation of the deceased individual. ... For details on how to determine whether GST or HST would apply to services other than funeral or cemetery services supplied in connection with a prepaid arrangement, refer to "Other services. ... Other services Some operators charge fees for other services that are not funeral or cemetery services, but that are supplied in connection with prepaid arrangements. ...