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The consideration has two components: 1) monetary consideration as rent, and 2) consideration from the undertaking of construction or improvements or both that will increase the value of the property. ... The timing of liability rules for supplies by way of lease, licence or similar arrangement apply in respect of the applicable consideration. ... One of the builder's clients supplies the builder with a used generator as part of the consideration for a cottage. ...

Be sure to take the following into consideration when preparing the T4A NR: Report the total gross amount of fees, commissions or other amounts paid. ...

Applicant Type- Corporation versus Individual Non-resident persons providing services through corporations, partnerships or joint ventures, or who have done so in the past, will be reviewed taking into consideration the total of their services provided in Canada over the period, both as an individual and through a corporation, partnership or joint venture. ...

Contact us For more information regarding double taxation cases and advance pricing arrangements, contact us at: International and Large Business Directorate Competent Authority Services Division 427 Laurier Avenue West 8th Floor, Enterprise Building Ottawa ON K1A 0L5 Fax: 613-990-7370 email: MAP-APA.PAA-APP@cra-arc.gc.ca Office of the Director – Competent Authority Services Division Negus, Cindy – Director, 613-946-6022 Mutual Agreement Procedure – Advance Pricing Arrangement Section 1: Nguyen, Tam – Manager, 613-941-9281 Section 2: Quinn, Dan – Manager, 613-952-6960 Section 3: Dukkipati, Sudha – Manager, 613-946-8897 Section 4: Busby, Brian – Manager, 613-946-6169 Mutual Agreement Procedure – Technical Cases Boychuk, Daryl – Manager, 613-946-6085 Advance Pricing Arrangement- Mutual Agreement Procedure – Economic Analysis Nayak, Govindaray – Chief Economist, 613-946-5162 For more information concerning the application of tax treaties where specific taxpayers are not involved, non-discrimination, recognition of foreign pension plans under treaties, and consideration of requests under paragraph 6, of Article XXIX A (Limitation on Benefits) in the Canada-US Tax Convention, contact us at: Tax Treaties Section Legislative Policy Directorate Legislative Policy and Regulatory Affairs Branch 6th Floor, Tower A Place de Ville 320 Queen Street Ottawa ON K1A 0L5 Blair Hammond Tel: 613-670-9653 Email: LPRA/PLAR.LOB@cra-arc.gc.ca Date modified: 2016-11-15 ...

Answer 2 a) The Canadian competent authority will accept a case under the MAP that involves a request for a downward adjustment in these circumstances: The upward adjustment has been accepted for consideration by the foreign tax authority; The foreign competent authority tries to resolve the case under the MAP. ...

The person with the lower salary should then take into consideration the deduction with respect to the clergy residence for the same accommodation. ...

The CRA will take into consideration the specific facts of each case, and will exercise this discretionary authority in a fair and judicious manner. ...

However, only those selected for further consideration will be contacted. ...

During these sessions the Agency applied a set of core principles and considerations to the proposed options to ensure strategic alignment. ...

Tax payable of $3,000 or less You do not have to make instalment payments on your federal taxes if the total of your taxes payable under Parts I, VI, VI.1, and XIII.1 determined before taking into consideration specified future tax consequences prior to the deduction of current-year refundable tax credits, for either the current or previous year, is $3,000 or less. ...