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Contents Application Summary Discussion and Interpretation General (¶s 1-2) Taxable dividends paid (¶s 3-6) Refundable dividend tax on hand (¶ 7) Refundable portion of Part I tax (¶s 8-9) Canadian and foreign investment income (¶s 10-19) Other considerations (¶s 20-22) Dividend refund rate Refundable dividend tax on hand Part I tax addition to RDTOH Definitions Aggregate investment income Eligible portion Foreign investment income Income or loss Refundable tax on CCPC's investment income Explanation of Changes Application This bulletin cancels and replaces Interpretation Bulletin IT-243R3 dated May 21, 1985, and the Special Release to IT-243R3 dated December 30, 1987. ... Other considerations ¶ 20. When determining the required tax instalments for a taxation year under section 157, paragraph 157(3)(b) allows each instalment to be reduced by one-twelfth of the dividend refund for that taxation year. ...

Contents Application Summary Discussion and Interpretation General (¶s 1-2) Taxable dividends paid (¶s 3-6) Refundable dividend tax on hand (¶ 7) Refundable portion of Part I tax (¶s 8-9) Canadian and foreign investment income (¶s 10-19) Other considerations (¶s 20-22) Dividend refund rate Refundable dividend tax on hand Part I tax addition to RDTOH Definitions Aggregate investment income Eligible portion Foreign investment income Income or loss Refundable tax on CCPC's investment income Explanation of Changes Application This bulletin cancels and replaces Interpretation Bulletin IT-243R3 dated May 21, 1985, and the Special Release to IT-243R3 dated December 30, 1987. ... Other considerations ¶ 20. When determining the required tax instalments for a taxation year under section 157, paragraph 157(3)(b) allows each instalment to be reduced by one-twelfth of the dividend refund for that taxation year. ...

Although automobile taxable benefits, including standby charges, may not involve an expenditure incurred in the year, in practice an amount in respect of such benefits can be included as salary or wages if the amount represents a reasonable estimate of the actual costs incurred and does not include any GST / HST or PST (unless no input tax credit refund was claimed) and the automobile expenses and CCA to which the standby charge relates are not included in calculating business income. 3.2 GST / HST or PST considerations Some taxable benefits (for example, non-cash benefits) included on the employee's T4 slip may include a GST / HST or PST component. ... Generally, the corporation is to reduce the related expenditure by the amount, if any, by which (i) the fair market value of the share exceeds (ii) that portion of the amount of the consideration that the issuing corporation has received for issuing the share that is added to, and not deducted because of a provision of the Income Tax Act from, the paid-up capital of the class of shares that includes the share. ... The nature and sources of available information will be a key consideration in developing an appropriate labour allocation method. ...

Slide 25 – Anti-terrorism considerations Dylan: Like all activities that a charity enters into, a charity is responsible for making sure that it does not support terrorist activities, including by making a grant to an individual or group that is engaged in or supports terrorist activities. ...

Although automobile taxable benefits, including standby charges, may not involve an expenditure incurred in the year, in practice an amount in respect of such benefits can be included as salary or wages if the amount represents a reasonable estimate of the actual costs incurred and does not include any GST / HST or PST (unless no input tax credit refund was claimed) and the automobile expenses and CCA to which the standby charge relates are not included in calculating business income. 3.2 GST / HST or PST considerations Some taxable benefits (for example, non-cash benefits) included on the employee's T4 slip may include a GST / HST or PST component. ... Generally, the corporation is to reduce the related expenditure by the amount, if any, by which (i) the fair market value of the share exceeds (ii) that portion of the amount of the consideration that the issuing corporation has received for issuing the share that is added to, and not deducted because of a provision of the Income Tax Act from, the paid-up capital of the class of shares that includes the share. ... The nature and sources of available information will be a key consideration in developing an appropriate labour allocation method. ...

Financial Claim Review Manual – Review procedures for financial reviewers SR&ED Program Previous chapter Table of contents Next chapter Chapter 6.0 Finalizing the Review Table of contents 6.1 Summary of chapter 6.2 Requirements of the chapter 6.3 Introduction 6.4 Reports to document the results of the review 6.4.1 The SR&ED financial review report 6.4.1.1 Contents of the SR&ED financial review report 6.4.2 Short SR&ED financial review report 6.4.3 Penalty recommendation report 6.4.4 Taxpayer relief (fairness) report 6.4.5 Documentation for Headquarters 6.5 Forms for finalizing an SR&ED claim review 6.5.1 T7W-9 and T7W-C 6.5.1.1 Amalgamations 6.5.1.2 Non-capital loss application on T7W-9 6.5.2 T99A- T2 Tax Calculation Information Sheet 6.5.2.1 Area A – Multiple jurisdictions 6.5.2.2 Area B – Calculation of taxable income – Loss carryback 6.5.2.3 Area C – Changes in investment income and income from active business 6.5.2.4 Area D – Small business deduction 6.5.2.5 Area E – Manufacturing and processing profits deduction 6.5.2.6 Area F – Part IV Tax (private and subject public corporation at any time during the year) 6.5.2.7 Area G – Dividend refund 6.5.2.8 Area H – Surtax credit (1992 and subsequent years) 6.5.2.9 Area I – Federal investment tax credit (Subsection 127(5) of the Act) 6.5.2.10 Area J – Section 163 penalties 6.5.2.11 Area K – Appeal 6.5.3 Revised schedules 6.6 Audit Information Management System 6.7 Assessments 6.7.1 Legislative authority 6.7.2 Normal reassessment period (statute-barred date) 6.7.3 Nil assessment – Notification 6.8 Loss determination 6.8.1 Loss determination statement 6.9 T2 Corporation Income Tax Returns approaching the statute-barred date 6.9.1 Processing procedures 6.10 Preassessment refund 6.11 Loss carryback administrative procedures 6.12 Revision of capital cost allowance, SR&ED expenditures and other permissive deductions 6.13 Retention of hard copy (paper) documents 6.14 Permanent documents 6.15 Indexing and organization of working papers 6.15.1 Indexing and cross-referencing 6.16 Additional considerations for large files 6.17 Checklist for the assembly of the SR&ED review file 6.18 Assembling the file for (re)assessing 6.19 Processing the SR&ED File This is a message which indicates that the Claim Review Manual for SR&ED financial reviewers is now effective and that the public severed version is available. 6.1 Summary of chapter This chapter discusses the procedures for finalizing the review. The main topics of this chapter are: 6.2 Requirements of the chapter 6.3 Introduction 6.4 Reports to document the results of the review 6.5 Forms for finalizing an SR&ED claim review 6.6 Audit Information Management System 6.7 Assessments 6.8 Loss determination 6.9 T2 Corporation Income Tax Returns approaching the statute-barred date 6.10 Preassessment refund 6.11 Loss carryback administrative procedures 6.12 Revision of capital cost allowance, SR&ED expenditures and other permissive deductions 6.13 Retention of hard copy (paper) documents 6.14 Permanent documents 6.15 Indexing and organization of working papers 6.16 Additional considerations for large files 6.17 Checklist for the assembling of the SR&ED review file 6.18 Assembling the file for (re)assessing 6.2 Requirements of the chapter This chapter outlines what is required to finalize the SR&ED review. ... Refer to Chapter 5.10.2 for details. 6.16 Additional considerations for large files Once again the FR should consult with the LFCM to determine if the SR&ED adjustments will be assessed independently or concurrently with the adjustments of other audit functions. ...

Financial Claim Review Manual – Review procedures for financial reviewers SR&ED Program Previous chapter Table of contents Next chapter Chapter 6.0 Finalizing the Review Table of contents 6.1 Summary of chapter 6.2 Requirements of the chapter 6.3 Introduction 6.4 Reports to document the results of the review 6.4.1 The SR&ED financial review report 6.4.1.1 Contents of the SR&ED financial review report 6.4.2 Short SR&ED financial review report 6.4.3 Penalty recommendation report 6.4.4 Taxpayer relief (fairness) report 6.4.5 Documentation for Headquarters 6.5 Forms for finalizing an SR&ED claim review 6.5.1 T7W-9 and T7W-C 6.5.1.1 Amalgamations 6.5.1.2 Non-capital loss application on T7W-9 6.5.2 T99A- T2 Tax Calculation Information Sheet 6.5.2.1 Area A – Multiple jurisdictions 6.5.2.2 Area B – Calculation of taxable income – Loss carryback 6.5.2.3 Area C – Changes in investment income and income from active business 6.5.2.4 Area D – Small business deduction 6.5.2.5 Area E – Manufacturing and processing profits deduction 6.5.2.6 Area F – Part IV Tax (private and subject public corporation at any time during the year) 6.5.2.7 Area G – Dividend refund 6.5.2.8 Area H – Surtax credit (1992 and subsequent years) 6.5.2.9 Area I – Federal investment tax credit (Subsection 127(5) of the Act) 6.5.2.10 Area J – Section 163 penalties 6.5.2.11 Area K – Appeal 6.5.3 Revised schedules 6.6 Audit Information Management System 6.7 Assessments 6.7.1 Legislative authority 6.7.2 Normal reassessment period (statute-barred date) 6.7.3 Nil assessment – Notification 6.8 Loss determination 6.8.1 Loss determination statement 6.9 T2 Corporation Income Tax Returns approaching the statute-barred date 6.9.1 Processing procedures 6.10 Preassessment refund 6.11 Loss carryback administrative procedures 6.12 Revision of capital cost allowance, SR&ED expenditures and other permissive deductions 6.13 Retention of hard copy (paper) documents 6.14 Permanent documents 6.15 Indexing and organization of working papers 6.15.1 Indexing and cross-referencing 6.16 Additional considerations for large files 6.17 Checklist for the assembly of the SR&ED review file 6.18 Assembling the file for (re)assessing 6.19 Processing the SR&ED File This is a message which indicates that the Claim Review Manual for SR&ED financial reviewers is now effective and that the public severed version is available. 6.1 Summary of chapter This chapter discusses the procedures for finalizing the review. The main topics of this chapter are: 6.2 Requirements of the chapter 6.3 Introduction 6.4 Reports to document the results of the review 6.5 Forms for finalizing an SR&ED claim review 6.6 Audit Information Management System 6.7 Assessments 6.8 Loss determination 6.9 T2 Corporation Income Tax Returns approaching the statute-barred date 6.10 Preassessment refund 6.11 Loss carryback administrative procedures 6.12 Revision of capital cost allowance, SR&ED expenditures and other permissive deductions 6.13 Retention of hard copy (paper) documents 6.14 Permanent documents 6.15 Indexing and organization of working papers 6.16 Additional considerations for large files 6.17 Checklist for the assembling of the SR&ED review file 6.18 Assembling the file for (re)assessing 6.2 Requirements of the chapter This chapter outlines what is required to finalize the SR&ED review. ... Refer to Chapter 5.10.2 for details. 6.16 Additional considerations for large files Once again the FR should consult with the LFCM to determine if the SR&ED adjustments will be assessed independently or concurrently with the adjustments of other audit functions. ...

For example, the entity could hold assets for a customer of a related entity, or consideration is paid to a related entity, either as an identifiable payment or as one element of a consolidated payment. ... Other considerations 10.78 A Canadian financial institution may receive a self-certification from an entity that is not resident in Canada that it is a financial institution. ... If this is an important consideration for a financial institution in connection with its initial transition to the Part XVIII regime, it can act accordingly so long as there is no delay of more than six calendar days, the transition procedure is documented, and the purposes of the Agreement are not frustrated by any such scheduling. ...

These are calculated by reference to a specified index upon a notional principal amount in exchange for specified consideration or a promise to pay similar amounts.); an insurance contract or an annuity contract; and any option or other derivative instrument. 6.28 Insurance contracts and annuity contracts are not considered to be custodial accounts. ... Other considerations 10.60 A Canadian financial institution may receive a self-certification from an entity that is not resident in Canada that it is a financial institution. ... If this is an important consideration for a financial institution in connection with its initial transition to the Part XVIII regime, it can act accordingly so long as there is no delay of more than six calendar days, the transition procedure is documented, and the purposes of the Agreement are not frustrated by any such scheduling. ...

Consideration must be given to any purpose or function for which the entity is licensed or regulated (including those of any predecessor). 3.11 There can be circumstances where an entity holds financial assets for a customer where the income attributable to holding the financial assets or providing related financial services belongs to (or is otherwise paid to) a related entity. For example, the entity could hold assets for a customer of a related entity, or consideration is paid to a related entity, either as an identifiable payment or as one element of a consolidated payment. ... Other considerations 9.83 A Canadian financial institution may receive a self-certification from an entity that is not resident in Canada that it is a financial institution. ...