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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. ...

The following conditions must be satisfied for a plan administrator to receive favourable consideration from the CRA: the member is an employee or former employee of the employer; the employer was a participating employer, and is undergoing insolvency proceedings under the Bankruptcy and Insolvency Act or Companies' Creditors Arrangement Act, and has ceased making contributions to the plan; LRBs have been reduced due to the plan’s underfunded status; the plan is not a designated plan; and the Minister has approved the application of subsection 8517(3.01) of the Regulations. ... In the case of an underfunded IPP, similar consideration may be provided as long as the lump-sum amount transferred from the plan represents the final payment from the IPP. ...

Image on screen: Tax considerations for Newcomers and Indigenous Peoples page Narrator: In the Tax considerations for Newcomers and Indigenous peoples section [callout surrounds the section and cursor clicks on the link], you’ll find additional information related to these specific clienteles as they often have unique tax filing requirements. ...

Company B can take into consideration the amount of CPP contributions and EI premiums previously withheld during the year on the 10 employees that were previously employed with Company A. ... Company A has not met the conditions of subsection 9(2) of the CPP or section 82.1 of the EIA and, therefore, may not take into consideration the amount of CPP contributions or EIA premiums previously deducted, remitted, or paid by Company B in 2020 for the new-hired employees. ...

However, in the case of a Canadian partnership the elective provisions of subsection 97(2) permit it to be transferred at an "agreed amount" which cannot exceed the fair market value of the work in progress and cannot be less than the consideration received by the transferor, but may be any amount between fair market value and nil (inclusive) when no consideration is received by the transferor. ...

Please refer to the current issue of Information Circular 71-17, Requests for Competent Authority Consideration Under Mutual Agreement Procedures in Income Tax Conventions, with respect to requests for competent authority consideration. ...

The monthly fee paid by the individuals to the organization is consideration for a supply of a service that includes accommodation, supervision, and assistance with personal hygiene, grooming, and dressing. ... If a transaction consists of multiple supplies, it is necessary to determine whether one of those supplies is incidental to another and whether it may consequently be deemed to form part of a single supply under other provisions of the Act (such as section 138, which applies where the main and the incidental supplies are made for a single consideration). ...

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. ...

We support the Government of Canada's commitment by using this approach in developing policies, procedures, and programs and by ensuring all Treasury Board submissions, Memoranda to Cabinet, and significant changes to the design and implementation of national programs and services include gender and other considerations. ... To this end, the CRA strives to earn the trust of Canadians by incorporating integrity and security considerations into every aspect of its strategic decision-making and daily operations. ...

Previously, legislative considerations were excluded from the committee’s scope; however, despite the change, there are boundaries to be respected that limit the Committee’s influence in the legislative arena and the types of recommendations the Committee may offer. 3. ... There was discussion on deterrence and performance measurement considerations insofar as these are affected by both taxpayer indifference to audit and strategies to resist and prolong the audit. ...