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Current CRA website

Excess Corporate Holdings Regime for Private Foundations

Related by family connection Related by a business or corporate connection What is a relevant person? ... Related by family connection Individuals are not at arm's length if they are related to each other by blood, marriage, adoption, or common-law relationship. ... Related by a business or corporate connection Even if individuals are not related by family connection, they may still be considered not at arm's length if they have close business or corporate connections. ...
Current CRA website

GST/HST and place of supply rules

Services rendered in connection with litigation Services rendered in connection with litigation The general rule for supplies of services will not apply to a service rendered in connection with criminal, civil or administrative litigation in a province. ... See examples – Supply of services rendered in connection with litigation Examples of supply of services rendered in connection with litigation Example 1 An individual from Brandon, Manitoba receives a speeding ticket in Kenora, Ontario. ... The service will be considered as having been made in Ontario because it is made in connection with litigation in Ontario. ...
Current CRA website

Questions and Answers about the GST/HST tax break for all Canadians

Do the various fees charged by establishments in connection with the provision of qualifying services related to the provision of food or beverages also qualify? ...
Current CRA website

Draft GST/HST Technical Information Bulletin B-103, Harmonized Sales Tax – Place of supply rules for determining whether a supply is made in a province

The supplier then only deals with the Quebec office in connection with the supply. ... If something else comes between the service and the property, the connection will not be considered to be direct. ... The business retains the same law firm to provide its services in connection with the litigation. ...
Current CRA website

Exports - Services and Intellectual Property

Services in connection with litigation services Sch. VI, Part V, s 23, paras 23(a) to (d) 43. ... Direct connection between service and property Policy statement P-169 45. ... If some object comes between the service and the property, the connection becomes more remote. ...
Current CRA website

Exports - Services and Intellectual Property

Services in connection with litigation services Sch. VI, Part V, s 23, paras 23(a) to (d) 43. ... Direct connection between service and property Policy statement P-169 45. ... If some object comes between the service and the property, the connection becomes more remote. ...
Current CRA website

Complaints and Disputes

You may hear a beep and experience a normal connection delay. La version française de cette publication est intitulée Plaintes et différends. ... You may hear a beep and experience a normal connection delay.): Individuals and non-resident trusts: 613-940-8495 Monday to Friday (except holidays) from 9:00 a.m. to 5:00 p.m. ... You may hear a beep and experience a normal connection delay. Electronic mailing lists We can notify you by email when new information on a subject of interest to you is available on our website. ...
Current CRA website

Instructions for applying for a tax shelter identification number

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. ...
Current CRA website

Income Tax Act – Authorization to exercise powers or perform duties of the Minister of National Revenue

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. ...
Current CRA website

Applicable rate of part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention

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. ...

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