Search - consideration

Currently, the legislation exempts supplies of property or services (excluding supplies of blood and blood derivatives) made by a public sector body if all or substantially all (90% or more) of the body's supplies of the property or service are made for no consideration. ... Bill C-4, if enacted, would also exclude from this exemption the supply of a parking space if the supply is made for consideration by way of lease, licence or similar arrangement in the course of a business carried on by a public sector body. ...

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). ...

Phase 2 of the audit has been included in the Audit, Evaluation, and Risk Branch’s (AERB) Risk-Based Audit and Evaluation Plan as part of the 2017-2019 Inventory of Engagements for Consideration. ... Procedures for Taxpayer Relief and/or other similar considerations are established and consistent with national guidelines, documented, and authorized. ...

This percentage decreases to 1% when we take into consideration the headquarters-regional exchange component. ...

Although the profile catalogues may address SoD considerations with respect to access privileges for a particular application, evidence was not available to demonstrate efforts to manage the risk of potential SoD issues on a horizontal basis. In addition, SoD considerations were not included in work moving forward to improve access management. ...

Much of the FOSO is based on these assumptions, best estimates, and judgment and gives due consideration to materiality. ... Certain services received on a without charge basis, including inter-entity transfers of tangible capital assets for nominal or no consideration, are recorded at the carrying amount. ...

Much of the FOSO is based on these assumptions, best estimates, and judgment and gives due consideration to materiality. ... Certain services received on a without charge basis, including inter-entity transfers of tangible capital assets for nominal or no consideration, are recorded for departmental financial statement purposes at the carrying amount. ...

As outlined in the above-noted information circular, the CASD will accept a request under the Mutual Agreement Procedure (MAP) that involves a request for a downward transfer pricing adjustment only in the following circumstances: A corresponding upward adjustment has been accepted for consideration by the foreign tax authority; The foreign competent authority takes steps to resolve the case under the MAP by reviewing the case, providing the Canadian competent authority with a detailed analysis as to why the foreign authority agrees with the adjustment and agrees to negotiate the case; The request for competent authority assistance is made within the time limits of the applicable treaty; and The issue is not one that the Canadian competent authority has decided, as a matter of policy, not to consider. 13. ... The taxpayer should be informed that the downward transfer pricing adjustment must be referred to the Assistant Director of Audit or the Director of the ITD for consideration of its appropriateness. ...

At the close of the most recent fiscal year, 35 applications were still under consideration for acceptance to the program (that is, instances where a pre-file meeting has occurred between the CRA and a taxpayer, but a taxpayer's acceptance to the program had yet to be granted by the close of the fiscal year). This figure alone, without any consideration of pre-file meetings that may take place in the coming year suggests that there could be as many as 35 new cases accepted into the program in fiscal year 2013-14. ...

For suggestions, the service feedback officer determines the appropriate business line and forwards the information to them for consideration. ... The program also collects compliments and feedback/suggestions, which are forwarded to the appropriate program for consideration. ...