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Election for nil consideration Under proposed subsection 157(2.1) a participating employer of a pension plan and a master pension entity of the pension plan would be permitted to jointly elect to have every actual taxable supply made by the participating employer to the master pension entity be deemed to have been made for no consideration. ... Therefore, the employer would be eligible to make the election to deem actual supplies made to the master pension entity as being made for no consideration. ... Therefore, neither employer would be eligible to make the election to deem actual supplies made to the master pension entity as being made for no consideration. ...

Considerations Progressive interventions The CRA manages non-compliance such as missing returns, unreported revenues, and incorrect deductions, using a range of progressive interventions. ... At the same time, the CRA will increase consideration of penalties for repeat offenders and focus its resources on high-risk audits and the most significant criminal investigations. ...

Excise and GST/HST News- No. 95 Table of Contents Form RC4616 – Simplified filing procedures concerning existing elections for nil consideration No offset of GST/HST and QST amounts for selected listed financial institutions with a consolidated filing election Service standard for responding to written requests for GST/HST rulings and interpretations Online services for GST/HST accounts Representatives – request or delete authorizations online Prescribed rates of interest What’s new in publications Enquiries Form RC4616 – Simplified filing procedures concerning existing elections for nil consideration As discussed in the Excise and GST/HST News – N o 91 and N o 94, section 156 of the Excise Tax Act permits corporations resident in Canada and Canadian partnerships that are: registrants engaged exclusively in commercial activities; and specified members of the same qualifying group to jointly elect to treat taxable supplies (with certain exceptions) made between them as having been made for no consideration. ... These parties must complete and file 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. ...

Assessment criteria and considerations The Board members continue to ensure the confidentiality of the information they have access to as they are bound by the confidentially provisions of the Income Tax Act, the Access to Information Act, and the Privacy Act. ... In choosing content, consideration is given to content that is published at different times of the year to determine if the organization is engaged in producing original news content on an ongoing basis. ... The Board’s review of the content is done with the lens of not only the Act, but also the administrative considerations set out in the Guidance, in particular, sections 2.23 – 2.38. ...

Assessment criteria and considerations The Board members continue to ensure the confidentiality of the information they have access to as they are bound by the confidentially provisions of the Income Tax Act, the Access to Information Act, and the Privacy Act. ... In choosing content, consideration is given to content that is published at different times of the year to determine if the organization is engaged in producing original news content on an ongoing basis. ... The Board’s review of the content is done with the lens of not only the Act, but also the administrative considerations set out in the Guidance, in particular, sections 2.23 – 2.38. ...

“Consideration” in this context refers to the fee charged by the guarantor for guaranteeing the corporate debt. ... A guarantee given by a non-shareholder without consideration, or for other than reasonable consideration, may not be considered a capital loss. ... It must be emphasized that REOP is only one consideration and not determinative on a stand-alone basis. ...

“Consideration” in this context refers to the fee charged by the guarantor for guaranteeing the corporate debt. ... A guarantee given by a non-shareholder without consideration, or for other than reasonable consideration, may not be considered a capital loss. ... It must be emphasized that REOP is only one consideration and not determinative on a stand-alone basis. ...

Other Considerations If you are a successful applicant, your references will be contacted to confirm that you meet the selection criteria above and that you have the following personal attributes: High ethical standards and integrity Sound judgement and confidentiality Diplomacy, tact, and discretion Collegiality Leadership and organization Diversity and Official Languages We are committed to the principles of employment equity. ...

Distress Preferred Shares Contents Application Summary Discussion and Interpretation GENERAL Introduction (¶s 1-2) Income Bonds and Income Debentures (¶ 3) Cost Considerations (¶ 4) Advance Income Tax Ruling (¶ 5) LEGISLATION Definition (¶ 6) Term (¶s 7-8) Companies Creditors' Arrangement Act (¶ 9) Determining Financial Difficulty (¶s 10-11) Use of Daylight Loans (¶ 12) Replacement of Debt (¶ 13) Use of Proceeds (¶s 14-17) STRUCTURE Description (¶s 18-19) Restrictions that apply to Newco (¶s 20-21) REQUESTING AN ADVANCE INCOME TAX RULING General (¶s 22-23) Excess Cash Flow (¶s 24-25) Rulings Procedures (¶s 26-27) Appendix I. ... Cost Considerations ¶ 4. The process of converting debt to distress preferred shares usually involves complicated banking, tax and corporate law considerations, resulting in significant legal and other costs. ... The main reason for this is that, taking into consideration the various business corporations acts, this structure affords creditors the most security with respect to the distress preferred shares received in substitution for their debt. ...

Distress Preferred Shares Contents Application Summary Discussion and Interpretation GENERAL Introduction (¶s 1-2) Income Bonds and Income Debentures (¶ 3) Cost Considerations (¶ 4) Advance Income Tax Ruling (¶ 5) LEGISLATION Definition (¶ 6) Term (¶s 7-8) Companies Creditors' Arrangement Act (¶ 9) Determining Financial Difficulty (¶s 10-11) Use of Daylight Loans (¶ 12) Replacement of Debt (¶ 13) Use of Proceeds (¶s 14-17) STRUCTURE Description (¶s 18-19) Restrictions that apply to Newco (¶s 20-21) REQUESTING AN ADVANCE INCOME TAX RULING General (¶s 22-23) Excess Cash Flow (¶s 24-25) Rulings Procedures (¶s 26-27) Appendix I. ... Cost Considerations ¶ 4. The process of converting debt to distress preferred shares usually involves complicated banking, tax and corporate law considerations, resulting in significant legal and other costs. ... The main reason for this is that, taking into consideration the various business corporations acts, this structure affords creditors the most security with respect to the distress preferred shares received in substitution for their debt. ...