Search - consideration

On inbound charges, again, the stock compensation component might be a relevant consideration in following the arm’s length principle. ... Other considerations would have to be considered if USco has Canadian employees or employees working in Canada. ...

In any particular case, it is a question of fact as to whether the specified individual was actively engaged on a regular, continuous and substantial basis in the business, which necessitates the consideration of various factors, including, among other things, the individual’s specific involvement and the nature of the business. ... In particular, the “excluded shares” and “reasonable return” exceptions should also be taken into consideration. ...

Notes From Presentation CRA cannot comment on all the considerations respecting the measuremnt of a benefit, which would be based on the facts and circumstances of each case. ...

It states, in part: The calculation of the amount or value of the benefit is usually based on the fair market rent for the property minus any consideration paid to the corporation by the shareholder for the use of the property. ... Any consideration paid for the use to the corporation by the non-resident shareholder, or the individual not dealing at arm’s length with them, for the use of the property is deducted from the imputed rent. ... What are some of the considerations that the legal representative should consider and document when asking for an extension? ...

A transferred his shareholding of Opco 1 (wholly-owned by him) to a corporation (Opco 2) equally owned by him and his spouse in consideration for a note. ... In consideration for the early termination of the lease, the new owner paid $15,000 to the tenant. ... The determination of when a corporation is wound up for the purposes of subsections 88(1) and 88(2) requires consideration of all facts and circumstances relevant to a particular situation. ...

The individual can then choose to claim the repayment as a deduction on the 2021 income tax and benefit return or request a reassessment on the 2020 income tax and benefit return to take into consideration the repayment made. ... If not, would consideration be given to reviewing these objections on an accelerated basis as they tend to deal with businesses that have been impacted by COVID-19. ... The CRA continues to evaluate the legislative provisions, privacy, and security considerations associated with signatures on other forms. ...

However, your suggestion will be taken into consideration as we evaluate the available options to modernize our contact centre technology. ... Please comment on the Agency's procedure for processing responses to processing reviews and whether the Agency could give consideration to allowing a number of uploads given there is a unique reference number provided for each processing review. ... We will take your suggestions into consideration and look into them further. ...

Headquarters will generally, in turn, refer the matter to the GAAR Committee for consideration. ... Taxpayers and their representatives should be assured that when the application of the GAAR is considered, all their arguments will receive careful consideration. ...

TEI invites a summary of CRA’s discussions with HMRC in respect of large business tax compliance, including whether (1) CRA is considering implementing a cooperative compliance program for large companies in Canada; (2) benchmarking exercises were conducted (or discussed) in respect of large file audit and issue resolution practices and procedures; and (3) any formal or informal joint initiatives between the respective tax authorities are under consideration or being implemented (or expanded) in respect of large file cases. ... All exchange of information requests, whether they occur under the auspices of JITSIC or otherwise are formal treaty-based exchanges and subject to the same considerations. ... In view of the easily accessible nature of electronic records through the internet — and in consideration of the decision in the Federal Court of Appeals decision in eBay Canada Ltd. ...

Do the split income rules apply where the management of a rental property held by a trust is provided by an external property manager (unrelated to the minor) who exclusively manages the property in consideration for a percentage of the gross rents? ... (“Oka”) took part in a series of transactions in the course of which inter alia they exchanged their shares of Oka in consideration for shares in the capital of another corporation, with the shares of a particular class (the “1971 FMV Shares”) having a low PUC and an ACB equal to their FMV. ... A wishes to extract Opco surplus other than as taxable dividends: A transfers those shares to a newly-incorporate corporation (“Holdco A”) in consideration for Holdco A shares, with the transferred shares’ ACB being the agreed amount in a s. 85(1) election. ...