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A promoter of a tax shelter includes a person who: sells or issues participating shares in the tax shelter promotes the sale, issuance, or acquisition of participating shares in the tax shelter acts as an agent or adviser for the sale or issuance of participating shares in the tax shelter acts as an agent or adviser to promote, sell, or acquire a participating interest in the tax shelter accepts consideration for his or her role in the tax shelter Example The CRA revoked the registration of Organization Z because, among other things, it promoted and provided private benefit to a tax shelter called TS Group. ... When an ineligible individual is a director, trustee, officer, or like official, or controls or manages a registered organization or applicant, the CRA may take the following into consideration in deciding the most appropriate course of action: What made the person an ineligible individual? ...

Summary – Late-payment surcharges Description Amount Purchase price $100 Plus GST ($100 × 5%) $5 Plus the surcharge $5 Customer pays $110 Gift certificates Gift certificates A gift certificate (including gift cards and online gift certificates) is generally a voucher, receipt, or ticket that: has a stated monetary value or is for a particular supply of property or a service is issued or sold for consideration is accepted as payment or partial payment of the consideration for a supply of property or service has only to be presented as a means of payment without any other obligation imposed on the holder has no intrinsic value Do not collect the GST/HST on the sale of a gift certificate. ...

Therefore, we would suggest that your concerns on this matter should be sent to the Minister of Finance for his consideration. ... Are there other considerations that apply to a determination of whether Employer B's contributions/payments would be considered eligible contributions under subsection 147.2(2) of the ITA assuming conditions in subsection 147.2(2)(a) are otherwise satisfied. ...

Each 5-year period can be with more than one employer In addition to the foreign service provisions set out in Newsletter No. 93-2, the CRA will give favourable consideration for the transfer of funds from a foreign pension plan to an RPP under subparagraph 8502(b)(v) of the Regulations, in order to allow the foreign service to be recognized under subparagraph 8503(3)(a)(v), when the following conditions are satisfied: The foreign pension plan is situated in a country that imposes an income tax and the plan qualifies for an exemption from tax, a reduced rate of tax or other favourable tax treatment that is provided under the laws of that country for pension plans. ... MEPs Where the plan is a MEP (including SMEPs), it is not necessary to take into consideration benefits payable under other plans. ...

If requested to do so, consideration will be given to a waiver of the remuneration rule if the employer certifies that for the year(s) under consideration: insufficient company earnings prevented the payment of the above minimum remuneration; no dividends were declared or paid to connected persons; no increase in retained earnings of the employer occurred; no retained earnings of the employer were transferred to a related corporation. ...

As described in subsection 7308(2), a retirement income fund is a qualifying retirement income fund at a particular time if the fund was entered into before 1993 and the carrier has not accepted any property as consideration under the fund after 1992 and at or before the particular time. In addition, a fund is a qualifying retirement income fund if the carrier has not accepted any property as consideration under the fund after 1992 and at or before the particular time, other than property from a retirement income fund that was a qualifying retirement income fund immediately before the transfer of property. ...

An individual may obtain a deduction under paragraph 60(l) in respect of all or part of amounts for the year they are included in the individual's income under subsection 146(8) to the extent they are paid (or in the case of a commutation payment received by a spouse as successor annuitant, to the extent it is directly transferred by the issuer of the RRSP) in the year or within 60 days after the end of the year: (c) as a premium under an RRSP under which the beneficiary is the annuitant; (d) to acquire a life annuity for the beneficiary or for the lives jointly of the beneficiary and the beneficiary's spouse, either with a guaranteed period that is not greater than 90 years minus the beneficiary's age or that of the beneficiary's spouse, at the time of its acquisition, or without a guaranteed period; (e) to acquire an annuity for the beneficiary for a term of years equal to 90 minus the beneficiary's age or, alternatively, 90 minus the age of the beneficiary's spouse, at the time of its acquisition; (f) to acquire an annuity under which a beneficiary child or grandchild (whether resident or non-resident), or a trust under which the child or grandchild is the sole person beneficially interested in all amounts payable under the annuity, is the annuitant for a term of years not exceeding 18 minus the age of the beneficiary at the time of its acquisition; or (g) to a carrier as consideration for a registered retirement income fund under which the beneficiary is the annuitant. ... Also, ¶ 27 indicates that annuity payments can be adjusted to (for example) take into consideration increases in the cost of living, and comments that a rollover to a registered retirement income fund is available. ¶ 28 is former ¶ 30 expanded to explain that a rollover is available when a subsection 146(8.91) election has been made. ¶ 29 is a general update of former ¶s 31 through 34 to reflect changes in the law discussed elsewhere in the bulletin and to reflect the change from a deduction to a non-refundable tax credit. ...

Question 3 In applying clause XXIX A(2)(e)(i) of the treaty, will the CRA take into consideration both the direct and indirect relevant shareholdings in a tested company to determine whether 50% or more of the relevant shares of the tested company are not owned, directly or indirectly, by persons other than qualifying persons? ... In this respect, subsection 248(26) of the Act clarifies that an amount that a debtor becomes liable to pay (other than interest) as consideration for any property acquired by, or services rendered to, the debtor shall, for the purposes of applying the provisions of the Act, be considered to be an obligation issued by the debtor equal to the amount of the liability. ...

Where title to the natural gas is transferred to a GST/HST registrant to facilitate storage of the gas, or to facilitate taking up the surplus gas until such time as the non-resident can take back the gas, it is a question of fact as to whether the consideration payable to the registrant by the non-resident is in respect of a service or of a supply of gas. Generally, a supply of storage services or of taking up surplus gas is zero-rated as a supply of a service included in section 15.3 of Part V of Schedule VI where the consideration attributable to the transfer of title to the gas is nil or nominal. 66. ...

Its objective is to facilitate impartial reviews, open discussions, and ethical considerations surrounding the Agency's day-to-day business, including operational and personnel areas. ... Its objective is to facilitate impartial reviews, open discussions, and ethical considerations surrounding the Agency's day-to-day business, including operational and personnel areas. 2.2 Administration and management of the Discipline Policy HRB has functional responsibility for the administration of the Discipline Policy. ...