Search - consideration

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. ...

The first that come to mind are the rollover provisions where if ACB is generated, there is an immediate income inclusion, so under section 85 for example, if property is transferred and non-share consideration is received in excess of the ACB of the transferred property, that would prompt an income inclusion- so: a similar result. ...

The guidance was careful to note that our administrative concessions in the guidance were not a promise that you would avoid Canadian residency, but rather that this new COVID situation and the restrictions on travel would be taken into consideration. ...

Turning to the question, in our view, a power of attorney under which a designated attorney exercises the voting rights of a controlling shareholder of a corporation as a consequence of the incapacity of that shareholder who continues to be the legal and beneficial owner of those shares would not constitute an external document that has to be taken into consideration in determining the de jure control of the corporation. ... New subsection 245(4.1) of the general anti-avoidance rule (“GAAR”) provides that if an avoidance transaction is significantly lacking in economic substance it is an important consideration that tends to indicate that the transaction results in a misuse or abuse under subsection 245(4). ...

CRA Panelists: Stéphane Prud'Homme, Director, Reorganizations Division Daryl Boychuk: Manager, Income Tax Rulings Directorate Q.1- Deferred safe Income and preferred shares The Canada Revenue Agency (CRA) has considered the allocation of safe income to preferred shares where a shareholder acquires preferred shares in a corporation as consideration for the transfer of a property (other than shares) on a tax-deferred basis to the corporation. ... Preliminary Response Prud'homme: As part of the Safe Income Paper, the CRA stated that, where a shareholder acquires preferred shares as consideration for the transfer of property on a tax deferred basis, the accrued gain on the property at the time of the transfer that is subsequently realized by the corporation would be viewed as contributing to the gain on the preferred shares, and accordingly would be included in the safe income of the preferred shares. ...

In light of the above, any changes to the Income Tax Act in this regard would be based on tax policy considerations. ... C, for FMV consideration. The three individuals were not related persons. 2010-0373131C6 confirmed the CRA view now contained in Folio S1-F5-C1 that there is a presumption that the shareholders of a private corporation having two or three unrelated shareholders will act together to exercise control of the corporation. ... D for FMV consideration. 2010-0373131C6 confirmed the CRA general position now contained in Folio S1-F5-C1 that in a situation where a private corporation has three unrelated shareholders, none of whom individually has control, the CRA presumes that the three shareholders act in concert, thereby forming a group that controls the corporation. ...

Authorized Representative (FIRP & ABSB) The Election or Revocation of an Election for Closely Related Corporations and/or Canadian Partnerships to Treat Certain Taxable Supplies as Having Been Made for Nil Consideration for GST/HST Purposes (RC4616) [i.e. the 156 election] is required to be signed by a person that is “authorized to file on behalf of the specified members…” The Canada Revenue Agency’s list of services for representatives of businesses (https://www.canada.ca/en/revenue-agency/services/e-services/represent-aclient/listservices-representatives-businesses.html) provides that Level 2, Level 3 and Legal Representatives access is required to be eligible to file an election. ... New GST/HST Memorandum 14.7, Closely Related Corporations, GST/HST Memorandum 14.5, Election to Deem Supplies to be Made for Nil Consideration, and GST/HST Memorandum 14.8, Closely Related Canadian Partnerships and Corporations for Purposes of Section 156 were also released in June 2023. ... Waive the annual requirement to file an application to use a pre-approved method where there are no changes from a method used in the prior year: Alternatively, consideration could be given to authorizing the use of a pre-approved method for three to five years with the condition that the reapplication for use of a pre-approved method for a particular fiscal year would arise where there is a material change in the business structure that would impact the ITC methodology. ...