Search - consideration

It is important to always provide all relevant information to CRA to allow for a complete consideration of the issue, at the assessing, audit, and objection stages. ... While an application for taxpayer relief from interest or penalties is under consideration, collection action will continue and the amount is due and payable. ...

Therefore, once an election is made pursuant to section 273, a co-venturer will not: include any consideration received for joint venture supplies made by the operator on its behalf when determining if it is a small supplier pursuant to section 148 its filing frequency pursuant to sections 245 to 249 unless it is associated with the operator (within the meaning of section 127), and include any GST/HST paid or payable on joint venture purchases made by the operator on its behalf when calculating its input tax credits. ... According to section 141.01, generally, the extent to which property or a service is consumed or used, or is to be consumed or used, in the course of a commercial activity depends on the extent to which the consumption or use, or intended consumption or use, is for the purpose of making taxable supplies for consideration. ...

Issue and Decision: According to section 138, "where (a) a particular property or service is supplied together with any other property or service for a single consideration, and (b) it may reasonably be regarded that the provision of the other property or service is incidental to the provision of the particular property or service, the other property or service shall be deemed to form part of the particular property or service so supplied. ... The non-profit organization charges a single consideration of $81.00 in respect of both supplies. ...

That formula is A- B, where A is the tax calculated on the deemed consideration and B is the total of the input tax credits that must be deducted from A. ... Paragraph (c) of the subsection states that the creditor is deemed to have received a supply of the property immediately before the supply to the recipient and for the same consideration as the supply to the recipient, which will normally reflect any improvements or capital expenditures. ...

The primary consideration is whether the taxpayer's actions in regard to the property in question were essentially what would be expected of a dealer in such a property. ... The fact that the taxpayer has a commercial background in similar areas or has had previous experience of a similar commercial nature has been held to be a pertinent consideration in some circumstances. ...

Terms and Conditions of Use In consideration of the Canada Revenue Agency (CRA) giving you access to the Dedicated Telephone Service (DTS), you agree to the following terms and conditions: You certify that all information provided by you relating to your registration is true, accurate and complete and that you meet the eligibility requirements for using the DTS as outlined on the DTS web page. ... Such a determination must take into consideration all of the particular facts and circumstances and is outside the scope of the DTS. ...

Gross income, net income, capital investment, cash flow, personal involvement and all other factors may be relevant considerations. ... However, consideration must be given to the fact that such a situation may arise in the first years of a farming operation or may be the result of extremely adverse weather conditions such as prolonged drought, severe hail, frost or flood. ...

The maximum capital cost allowance that may be claimed in respect of a particular mine or right is the lesser of (a) the amount computed by applying the rate established in accordance with 5 or 6 above to the number of units actually mined during the fiscal period under consideration, and (b) the undepreciated capital cost of the mine or right A taxpayer may, in lieu of claiming capital cost allowance as determined above for all his industrial mineral mines or rights, claim an amount not exceeding the lesser of (a) $100, or (b) the amount received by him in the taxation year from the sale of mineral In such case, the taxpayer, if he has more than one mine or right, may allocate the amount deducted among his mines and rights. ... Where land acquired as an industrial mineral mine is disposed of, the entire consideration received therefore is proceeds of disposition of depreciable property, namely, the industrial mineral mine, and is included in the calculation of the undepreciated capital cost of the class in which the mine is included under paragraph 13(21)(f). ...

In addition, the Board will give careful consideration to the CRA's collective bargaining recommendations to the Treasury Board. ... The Board will also examine the CRA's annual financial statements as part of its consideration of the Departmental Results Report for recommendation to the Treasury Board. ...

Paragraph 4 of the bulletin is revised for clarification and to take into consideration the amendment to the preamble of subsection 107(2) enacted under S.C. 1988, c.55 (formerly Bill C-139) applicable to distributions after 1987. ... Paragraph 5 of the bulletin is revised to take into consideration the amendment to the definition of "cost amount" in subsection 248(1) enacted under S.C. 1994, c.7 (formerly Bill C-15) applicable after May 22, 1985. ...