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When determining if land that is capital real property of an individual or personal trust is used primarily in a business rather than primarily in non-business uses immediately prior to its sale, consideration must be given to all uses of the land throughout the time it is owned by the individual or personal trust. 4. ... However, consideration should be given to possibility of section 196.1 applying in such circumstances Footnote 16. ... Footnotes Footnote 14 In the absence of legal restrictions such as minimum lot size or functional considerations such as needing additional land for road access, the amount of land considered to form part of the residential complex, i.e., the amount of land considered to be reasonably necessary for the use and enjoyment of the residential unit as a place of residence, would be restricted to a half hectare. ...

Section 156 provides a joint election that permits corporations resident in Canada and Canadian partnerships that are qualifying members of a qualifying group to treat certain taxable supplies between them as having been made for nil (or no) consideration if the requirements for the election are satisfied. ... For information about this election, refer to GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration, and Form RC4616, 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. ...

The joint election under subsection 156(2) permits two Canadian partnerships or a Canadian partnership and a corporation that is resident in Canada that are specified members of a qualifying group to treat certain taxable supplies between them as having been made for nil (or no) consideration. For information about the definitions of specified member and qualifying group, refer to GST/HST Memorandum 14-5, Election to Deem Supplies to be Made for Nil Consideration. 3. For information about this joint election and the conditions for being a specified member of a qualifying group, refer to GST/HST Memorandum 14-5 and Form RC4616, 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. 4. ...

In cases where one of the main purposes of a person's absence from Canada is to avoid Canadian taxes, which would otherwise be payable, consideration may be given to other factors in determining the person's residence status. ... However, because each province has its own guidelines and policy regarding eligibility for benefits after leaving Canada, continuing coverage under a provincial plan will not be considered to be a significant residential tie, but will be given consideration when reviewing all the facts.) the registration of property that is being taken outside Canada with Canada Customs; the rental of a safety deposit box or postal box in Canada; the listing of a telephone number in a telephone directory in Canada; the continued use of stationery and business cards with a Canadian address; and professional or other memberships in Canada (on a resident basis). 25. ... The value of consideration for these supplies is deemed to be the fair market value of the supply at the time the property is transferred or the service is rendered. ...

Election to not account for GST/HST on actual taxable supplies Effective for supplies made after March 21, 2013, the budget proposes to allow a participating employer of a pension plan and a pension entity of the pension plan to make a joint election to treat an actual taxable supply of property or a service by the employer to the pension entity as being made for no consideration where the employer accounts for and remits tax on the deemed supply of the property or service or on the consumption or use of inputs for the purpose of making the actual supply. ... Relief from accounting for tax on deemed taxable supplies Effective for fiscal years of an employer beginning after March 21, 2013, the budget also proposes that: A participating employer of a pension plan would be fully relieved from applying the deemed taxable supply rules in respect of the pension plan for a fiscal year where: an election with a pension entity of the pension plan to treat actual taxable supplies as being made for no consideration (discussed above) is not in effect for the employer; and the amount of the GST (including the federal part of the HST) that the employer was (or would have been, but for this measure) required to account for and remit under the deemed supply rules in respect of the pension plan in its preceding fiscal year is both less than $5,000 and less than 10% of the total net GST (including the federal part of the HST) paid by all pension entities of that pension plan in that preceding fiscal year. ... An employer that is entitled to relief under this provision would also be able to treat its actual taxable supplies as being for no consideration where the election, discussed above, is in effect. ...

During the last 2 fiscal years (2016 to 2017 and 2017 to 2018), significant changes have taken place within the Business Compliance Directorate, including: regionally centralizing workload development for trust account examinations shifting functional responsibility for the GST/HST and Air Travellers Security Charge programs to the GST/HST Registration & Filing Compliance Section implementing a new 3-tiered quality assurance program Taking into consideration the volume of money collected and the fact that the Trust Accounts Examination Program had never been audited, an internal audit to assess the existence and strength of the internal controls that support the governance of the programs was relevant and timely. 2. ... Recommendation 1 Further to the progressive evolution of the program, the Collections and Verification Branch should develop and implement file selection criteria to allow for a more holistic approach to risk assessment that takes into consideration the multiple business lines (Payroll, GST/HST, and Air Travellers Security Charge) and sources of workload (referrals, leads, and generated by Workload Development) to create a prioritized risk-based workload for the Trust Accounts Examination Program. ... In measuring the fiscal impact of the payroll files, no consideration is given to the extent of the examination officer’s work on the file or to the efforts of the Regional Workload Development Team in identifying the non-compliant taxpayers. ...

For individual taxpayer requests, the CRA has control structures in place to ensure that TR cases are resolved with due care and consideration. ... Consideration is also given to situations where taxpayers are unable to pay due to financial hardship. ... Conclusion The CRA has control structures in place to ensure that TR requests are resolved with due care and consideration. ...

Much of the Future-oriented Statement of Operations is based on these assumptions, best estimates, and judgment and gives due consideration to materiality. ... Yes (March 31, 2015) GHG emissions (CO2 equivalent) in fiscal year 2005-2006. 403 tonnes GHG emissions (CO2 equivalent) in current fiscal year. 318 tonnes Percentage change in GHG emissions from fiscal year 2005-2006 to the current fiscal year-21% Goal: Waste and asset management Target: Green procurement As of April 1, 2014, the CRA will continue to take action to embed environmental considerations into Crown procurement. ... Targeted performance level: Seeking to reach "Achieved" Implementation strategy element: Integrate environmental considerations into corporate policies, processes, and practices in accordance with departmental refresh cycles. ...

Learning and awareness: Commitment to SD appears in 100% (80) of senior manager (EX/SM) performance expectations and accountability agreements. 100% of RMT members recommended and supported development and implementation of local SD programs; SD leads identified at all responsibility centres SD Lens developed by HQ and distributed to regions in the third quarter of 2003-2004; all SD leads (15) provided with lens to help advise senior managers on integrating SD into business plans and proposals; SD appears as SMT standing agenda item at 75% of responsibility centres SD awareness presentation delivered to 95% of SOR senior managers SD considerations have been integrated into regional procurement training (WEBRO, WHMIS), new employee orientation packages, and local IT end-user training, and has appeared in employee information packages developed in support of major renovation and construction projects (Hamilton and St. ... The Materiel Management Directorate (MMD) updated the procurement certification program to include environmental considerations and green content. ... Information Technology Best practices: Used the Green Move Protocol to relocate staff to new IT campuses throughout the year Incorporated SD considerations into branch procurement of IT hardware, printers/ photocopiers (duplex-capable), and energy efficient monitors; recycled toner cartridges, diskettes, and CDs Reduced the number of printers, photocopiers, and fax machines on each floor to conserve energy and paper use (for example, the branch now has a ratio of 40 employees to 1 printer) Learning and awareness: Hosted regular lunch and learn session on various SD topics Promoted SD and wellness to employees through information provided on the branch Wellness Web site As an employees SD awareness activity, the branch collected 470 disposable cups in two days from five floors of the Fitzgerald Campus, and used the cups to make a Paper Cup Man to display in the foyer of the campus. ...

In order to ensure consideration of a treaty-based waiver application, it should be submitted at least 30 days prior to the commencement of the services in Canada or 30 days prior to the initial payment for the related services. ... Non-residents providing services through corporations, partnerships, or joint ventures or who have done so in the past, will be reviewed under the guidelines taking into consideration the total of their services provided in Canada in the period both as an individual, and through the corporation, partnership or joint venture. ... The geographic area to consider is relative to the industry and type of activity under consideration. ...