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The CRA considers the additional charge to be part of the consideration for the supply of the transportation service. As a result, the GST/HST is charged on the surcharge at the same rate as for the rest of the consideration for the transportation service. ...

Additional considerations for large files are included at or near the end of chapters 4, 5 and 6 to outline the particularities of processing such files, and the procedures for processing partnership claims for SR&ED are included in an appendix. There may be other particularities to take into consideration in processing SR&ED claims from other types of entities such as, individuals, limited partnerships, trusts, joint ventures, and cooperatives, which are not covered in the CRM. ...

For example a qualifying taxpayer is required to self-assess tax on the non-financial (“loading”) part of the consideration for an imported financial service where the parties are not dealing at arm’s length. Loading is defined as that part of the consideration for a financial service that is attributable to administrative expenses, profit and error margins, employee compensation, and other similar amounts. ...

. ¶1.9 (formerly included in ¶5 of IT-270R3) now includes a reference to documentary or stamp taxes in the examples of items not considered to be income or profits taxes in consideration of the CRA’s position on the general nature of these taxes. ¶1.10 (formerly included in ¶5 of IT-270R3) has been revised to change business income to net business income in the first sentence for greater clarity. ¶1.16 (formerly included in ¶7 of IT-270R3) now includes an example describing a taxpayer with different taxing and business countries. ¶1.25 (formerly included in ¶8 of IT-270R3) has been reworded to remove ambiguity as to whether foreign was meant to describe the other person or partnership and to better reflect paragraph (e) of the definition of non-business-income tax in subsection 126(7). ¶1.26 (formerly included in ¶8 of IT-270R3) now includes a reference to the amendments to the overseas employment tax credit contained in the Jobs and Growth Act, 2012; edited to remove redundancy. ¶1.29- 1.31 are new additions which replace and expand on the parenthetical comment in ¶8 of IT-270R3, which read: (subject to subsections 126(4.1) and (4.2), which concern the no economic profit and short-term security acquisitions rules, respectively) ¶1.32- 1.35 (formerly included in ¶11 of IT-270R3) has been revised to omit the last sentence of former ¶11 and to add a discussion on what is meant by paid by the taxpayer for the year. ¶1.39 replaces and expands on the partnership information contained within parenthesis at ¶1- 2 of IT-270R3. ¶1.41 (formerly included in ¶15 of IT-270R3) has been revised to de-emphasize the word spouse and place greater emphasis on the filing of a valid, foreign, communal return. ¶1.42 (formerly included in ¶16 of IT-270R3) has been expanded to reflect amendments to section 261 and the CRA’s position regarding consistency in exchange rate methodologies. ¶1.46 (formerly included in ¶20 of IT-270R3) has been revised to clarify the situation of income arising from property which pertains to or is incidental to a foreign business. ¶1.49 (formerly included in ¶21 of IT-270R3) now references the Canada-UK Income Tax Convention. ¶1.51 (formerly included in ¶22 of IT-270R3) now contains a sentence to address subsection 91(5). ¶1.52 is a new paragraph added to point out that where a treaty is applicable; the treaty may have its own income sourcing rules which supersede those of the Act, but only for the purposes of eliminating double taxation in accordance with the treaty. ¶1.53 (formerly included in ¶23 of IT-270R3) now includes the phrase or profit generating activities for greater clarity, as well as a bullet referencing transportation or shipping businesses. ¶1.54 is a new paragraph added to reflect the jurisprudence on additional factors and the weighting of various factors when determining the location of the source of the business income. ¶1.57 (formerly included in ¶25 of IT-270R3) has been revised to change place to physical place to remove ambiguity. ¶1.58 (formerly included in ¶26 of IT-270R3) contains new sentences that reflect additional factors concerning the situs of income and their weight, as judicially addressed. ¶1.62 (formerly included in ¶3 of IT-395R2) has been revised to add and title was transferred to the second sentence and to add the third sentence for greater clarity. ¶1.63 (formerly included in ¶3 of IT-395R2) has been revised to add the phrase under the Act to remove ambiguity and to differentiate between foreign deemed dispositions and deemed dispositions under domestic law. ¶1.65 (formerly included in ¶4 of IT-395R2) now includes examples and a discussion of the relative weighting of various factors for consideration. ¶1.69 is a new paragraph added to address TFSAs and RRSPs. ¶1.70- 1.72 (formerly included in ¶37 of IT-270R3) has been revised to reflect legislative changes effective for the 2005 and later tax years, to make reference to the additional definitions involved, and to reference Guide 5000-G, General Income Tax and Benefit Guide. ¶1.73 (formerly included in ¶40 of IT-270R3) has been revised to change the treaty in the example to the Canada-India Treaty. ¶1.76 (formerly included in ¶2 of IT-270R3) has been revised to match the marginal note of subsection 120(1). ¶1.79 (formerly included in ¶3 of IT-270R3) has been expanded to better explain the operation of section 114 and subparagraphs 126(1)(b)(ii) and 126(2.1)(a)(ii). ¶1.80 (formerly included in ¶30 of IT-270R3) now includes the phrase not under the laws of the foreign jurisdiction in the first paragraph for greater clarity. ...

As was the case last year when negotiating with the Public Service Alliance of Canada, these negotiations required that the CRA and the Board carefully balance the interests of the CRA while keeping in mind government-wide considerations, including the elimination of severance. ... Commissioner and Chief Executive Officer Canada Revenue Agency Ottawa, Ontario committee membership and director participation The Board of Management is supported by four committees that undertake much of the detailed review of items brought before the Board for the Board's 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 on any undisputed amount and the amount is due and payable. ...

Other promoters stated their requests were very complex and required additional tasks, including: driving applicants to medical appointments, pre-screening DTC applications to ensure that only valid DTC requests are submitted to the CRA, following up with medical practitioners to ensure that the right information is given on the DTC certificate, operating their own call centres to support their clients, advertisement and office overhead, geographic considerations for overhead expenses, postage for shipping documents across Canada to obtain doctor reports and signatures on the DTC certificate, and adjusting multiple tax returns for anyone who could have supported the person with a disability. ... The CRA will continue its efforts to constantly improve the service it offers to Canadians by addressing the items that can be acted on in the short term and give due consideration to other items as part of our long term strategy. ...

Consideration should be given to introducing higher-level sign-off requirements in cases involving substantial amounts of evaded taxes, complex arrangements, or new issues of law. ... Consideration should be given to introducing procedures to ensure that large or complex cases are reviewed by specialists before acceptance into the VDP. ...

Otherwise, the additional consideration (i.e., the amount that is over and above the FMV) that was paid to the corporation may be considered to be assistance for the purposes of calculating the CPTC or the PSTC, or an acquisition of interest in the corporation or the corporation’s business or property, depending on the facts and circumstances of the situation. ... In the case of film and video productions, crowdfunding allows producers to finance, in whole or in part, their projects or promotional activities usually in return for non-monetary considerations offered to contributors (i.e., the donation model). ...

(Black's Law Dictionary) settlor means one who furnishes the consideration for the creation of a trust, though in form the trust is created by another. ... Transfer of Title to and from the Trustee Sections 268 and 269 of the Act provide that where a person settles property in an inter-vivos trust and where the trustee distributes property of the trust to the beneficiaries, the settling or distribution of the property is deemed to be a supply for consideration equal to the amount determined under the Income Tax Act. ...