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However, it must be established that there is SR&ED (refer to the Guidelines on the Eligibility of Work for SR&ED Tax Incentives) before any consideration is given to the type of asset resulting from the SR&ED. ... Therefore, a pilot plant is sized taking into consideration the SR&ED to be conducted in / on it. ... What is important is that the determination of the type of the asset must take into consideration the facts of the actual use made of the facilities and equipment. ...

Examples of subjective audit issues, in the context of negotiating and executing an audit agreement, include: Income tax issues: valuation of certain benefits, equity, services or property (e.g. market rate vs. bulk rate); business purpose; reasonableness of expenses; consideration for supply (e.g. determining fair market value); timing of an event (e.g. a change in use of property, when a hobby becomes a business, etc.); legitimate doubt or ambiguity regarding the interpretation of a legislative provision in relation to the particular facts where more than one view could be consistent with existing case law and CRA interpretive positions; employed vs. self-employed; or residency issues. ... These considerations should be adequately documented in the audit file. ... If the taxpayer has legal representation, or if the taxpayer has provided a draft audit agreement and waiver document, then consideration should be given to involving CRA Legal Services unless the matter is routine. ...

Any rent, royalty or similar payment, whether it be for "know-how", for the use of confidential technical information, or for any other consideration, is subject to tax under paragraph 212(1)(d) unless it falls within the exceptions described in subparagraphs (vi) through (x). ... Under this provision any payment for information concerning industrial, commercial or scientific experience will be subject to tax where the total amount payment as consideration for such information is dependent in whole or in part upon: (a) the use to be made thereof or the benefit to be derived therefrom; (b) production or sales of goods or services, or (c) profits. 15. ... Under this provision any payment for services of an industrial, commercial or scientific character performed by a non-resident person will be subject to tax where the total amount payable as consideration for such services is dependent in whole or in part upon: (a) the use to be made thereof or the benefit to be derived therefrom; (b) production or sales of goods or services; or (c) profits 21. ...

We may give special consideration for an earlier effective registration date where there is a transfer of assets between plans related to a buy/sell agreement for the ongoing pension coverage of the plan members. ... The person who is the administrator, or the majority of persons who form the body that is the administrator, must be resident in Canada except as otherwise allowed in writing by the Minister. 2.5.1 Non-Resident Administrator Consideration will be given to allow a non-resident to be the plan administrator. ... A letter of undertaking from the non-resident administrator confirming the above-mentioned requirements must be provided prior to our consideration for approval. ...

A "recipient" is defined, in part, as the person who is liable to pay the consideration in respect of a supply. ... Generally, for the insured to be considered the recipient of the supply related to repairing or replacing the property, the invoice must name the insured as the purchaser and the insured must be the person legally liable to the supplier for payment of the consideration for the supply. ... GST/HST forms E412- Notice of Revocation of Waiver GST59- GST/HST Return for Imported Taxable Supplies and Qualifying Consideration GST62- Goods and Services Tax/Harmonized Sales Tax (GST/HST) Return (Non-personalized) GST66- Application for GST/HST Public Service Bodies' Rebate and GST Self-government Refund GST74- Election and Revocation of an Election to use the Quick Method of Accounting GST111- Financial Institution GST/HST Annual Information Return GST190- GST/HST New Housing Rebate Application for Houses Purchased from a Builder GST287- Election or Revocation of the Election by Public Service Bodies to Use the Special Quick Method of Accounting GST303- Application to Offset Taxes by Refunds or Rebates RC79- Deposit Advice RC199- Voluntary Disclosures Program (VDP)- Taxpayer Agreement RC7066-SCH- Provincial Schedule- GST/HST Public Service Bodies' Rebate GST/HST guides RC4027- Doing Business in Canada- GST/HST Information for Non-Residents RC4028- GST/HST New Housing Rebate RC4419- Financial Institution GST/HST Annual Information Return GST/HST info sheets GI-066- How a Charity Calculates the Net Tax to be Reported on its GST/HST Return (revised) GI-067- Basic GST/HST Guidelines for Charities (revised) GI-068- Basic GST/HST Guidelines for Public Institutions (revised) GI-106- Ontario First Nations Point-of-Sale Relief- Reporting Requirements for GST/HST Registrant Suppliers (revised) GI-118- Builders and GST/HST NETFILE GI-119- Harmonized Sales Tax – New Place of Supply Rule for Sales of Specified Motor Vehicles GI-120- Assignment of a Purchase and Sale Agreement for a New House or Condominium Unit GI-121- Determining Whether a Public Service Body is Resident in a Province for Purposes of the Public Service Bodies' Rebate GST/HST memoranda 17-14- Election for Exempt Supplies GST/HST technical information bulletins B-102- First Nations Goods and Services Tax- Place of Supply (revised) Excise duty notices EDN30- Tobacco Marking Requirements under the Amended Stamping and Marking of Tobacco Products Regulations Softwood lumber products export charge notices SWLN39- Termination of the 10% Additional Export Charge and Refund of Overpayments SWLN40- Surge Charge – Alberta Region (June 2011) All GST/HST, Excise Duty, and Excise Taxes and Special Levies publications can be found on the CRA Web site at www.cra.gc.ca/gsthsttech, at www.cra.gc.ca/etsl, and at www.cra.gc.ca/exciseduty. ...

As part of the Government of Canada’s initiative to implement a federal greenhouse gas emissions pricing structure, and taking into consideration provincial greenhouse gas emissions pricing systems, the Government has developed a federal carbon pollution pricing system composed of a fuel charge that applies on fossil fuels and an output‑based pricing system for industrial facilities. ... Excise forms B249 Air Travellers Security Charge Return B273 Excise Return- Cigarette Inventory Tax B300 Cannabis Duty and Information Return under Excise Act, 2001 RC627 Agreement Among Related or Associated Brewers for the Allocation of Production Volume Limits RC633 Beer Revenue Worksheet RC634 Credit Claim Worksheet Excise duty circulars ED212-11 Application of Rates of Excise Duty on the First 75,000 Hectolitres of Beer Brewed in Canada ED212-12 Related or Associated Persons Rules for Brewers Excise duty memoranda EDM1-1-2 Regional Excise Duty Offices (revised) Excise duty notices EDN52 Obtaining and Renewing a Cannabis Licence EDN53 General Information for Cultivators, Producers and Packagers of Cannabis Products EDN54 General Overview of the Cannabis Excise Stamps EDN55 Calculation of Cannabis Duty and Additional Cannabis Duty on Cannabis Products GST/HST guides RC4022 General Information for GST/HST Registrants RC4027 Doing Business in Canada- GST/HST Information for Non-Residents GST/HST info sheets GI-118 Builders and GST/HST NETFILE GST/HST memoranda 3-6 Conversion of Foreign Currency GST/HST notices NOTICE308 GST/HST and Investment Limited Partnerships GST/HST forms GST29 Educational Services- Election and Revocation of the Election to Make Certain Supplies Taxable GST30 Election for Passenger Vehicles or Aircraft to be Deemed to be Used Exclusively in Non-Commercial Activities GST31 Application by a Public Service Body to Have Branches or Divisions Designated as Eligible Small Supplier Divisions GST32 Application to Deem One Unincorporated Organization to Be a Branch of Another Unincorporated Organization GST44 Election Concerning the Acquisition of a Business or Part of a Business GST59 GST/HST Return for Imported Taxable Supplies, Qualifying Consideration, and Internal and External Charges GST60 GST/HST Return for Purchase of Real Property or Carbon Emission Allowances GST66 Application for GST/HST Public Service Bodies' Rebate and GST Self-Government Refund GST70 Election or Revocation of an Election to Change a GST/HST Fiscal Year GST71 Notification of Accounting Periods for GST/HST GST74 Election and Revocation of an Election to Use the Quick Method of Accounting GST111 Financial Institution GST/HST Annual Information Return GST145 Waiver of the Limitation Period for Assessment GST146 Notice of Revocation of Waiver GST189 General Application for Rebate of GST/HST GST190A GST/HST New Housing Rebate- Appendix A GST191 GST/HST New Housing Rebate Application for Owner-Built Houses GST192 GST/HST Transitional Rebate Application for Builders of New Housing on Leased Land GST193 GST/HST Transitional Rebate Application for Purchasers of New Housing GST287 Election or Revocation of the Election by Public Service Bodies to Use the Special Quick Method of Accounting GST288 Supplement to Forms GST189 and GST498 GST303 Application to Offset Taxes by Refunds or Rebates GST322 Certificate of Government Funding GST367 Endorsement to the Bond for Non-Resident Person Without a Permanent Business Establishment in Canada GST370 Employee and Partner GST/HST Rebate Application GST386 Rebate Application for Conventions GST488 Election or Revocation of an Election Not to Use the Net Tax Calculation for Charities GST489 Return for Self-Assessment of the Provincial Part of Harmonized Sales Tax (HST) GST494 Goods and Services Tax/Harmonized Sales Tax (GST/HST) Final Return for Selected Listed Financial Institutions GST495 Rebate Application for Provincial Part of Harmonized Sales Tax (HST) GST498 GST/HST Rebate Application For Foreign Representatives, Diplomatic Missions, Consular Posts, International Organizations, Or Visiting Forces Units GST499-1 First Nations Tax (FNT) Schedule GST502 Election and Revocation of Election Between Auctioneer and Principal GST506 Election and Revocation of an Election Between Agent and Principal GST507 Third Party Authorization and Cancellation of Authorization for GST/HST Rebates GST518 GST/HST Specially Equipped Motor Vehicle Rebate Application GST523-1 Non-profit organizations- Government Funding GST524 GST/HST New Residential Rental Property Rebate Application GST525 Supplement to the New Residential Rental Property Rebate Application- Co-op and Multiple Units GST528 Authorization to Use an Export Distribution Centre Certificate GST531 Return for Self-Assessment of the First Nations Goods and Services Tax (FNGST) GST532 Agreement and Revocation of an Agreement Between Supplier and Constructive Importer RC1 Request for a Business Number RC59 Business Consent for Offline Access RC59X Cancel Business Consent or Delegated Authority RC151 GST/HST Credit Application for Individuals Who Become Residents of Canada RC4530 Election or Revocation of an Election to Use a Production Proxy to Report the Recapture of Input Tax Credits RC4531 Election or Revocation of an Election to Use the Estimation and Reconciliation Method to Report the Recapture of Input Tax Credits RC4600 Election or Revocation of an Election Under Subsection 217.2(1) RC4607 GST/HST Pension Entity Rebate Application and Election 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 RC4618 Election or Revocation of an Election for GST/HST Purposes to have a Pension Entity be the Designated Pension Entity in Respect of a Master Pension Entity RC7000-PE Prince Edward Island Provincial Sales Tax Transitional New Housing Rebate RC7001-PE Prince Edward Island Provincial Sales Tax Transitional New Housing Rebate- Residential Condominiums RC7002-PE Prince Edward Island Provincial Sales Tax Transitional New Housing Rebate- Apartment Buildings RC7003-PE Prince Edward Island Provincial Sales Tax Transitional New Housing Rebate for Non-registrant First Resellers RC7003-ON Ontario Retail Sales Tax (RST) Transitional New Housing Rebate for Non-registrant First Resellers RC7004-BC British Columbia Transition Tax Rebate RC7066-SCH Provincial Schedule- GST/HST Public Service Bodies' Rebate RC7190-BC GST190 British Columbia Rebate Schedule RC7190-NS GST190 Nova Scotia Rebate Schedule RC7190-ON GST190 Ontario Rebate Schedule RC7190-WS GST190 Calculation Worksheet RC7191-BC GST191 British Columbia Rebate Schedule RC7191-ON GST191 Ontario Rebate Schedule RC7207 GST/HST Rebate Application and Election for GST/HST and QST Purposes for Pension Entities that are Selected Listed Financial Institutions RC7207-1 QST Rebate Application and Election for Pension Entities that are Selected Listed Financial Institutions for GST/HST Purposes Only RC7218 Elections or Revocation of Elections for GST/HST and/or QST Purposes to Designate a Pension Entity that is a Selected Listed Financial Institution in Respect of a Master Pension Entity RC7220 Election for GST/HST and QST Reporting Period for a Selected Listed Financial Institution RC7220-1 Notice of Revocation of an Election for GST/HST and QST Reporting Period by a Selected Listed Financial Institution RC7244 Elections Concerning the Acquisition of a Business or Part of a Business by a Recipient that is a Selected Listed Financial Institution for QST Purposes RC7245 Waiver of the Limitation Period for Assessment of a Selected Listed Financial Institution RC7246 Notice of Revocation of Waiver for Selected Listed Financial Institution (subsection 298(8) of the Excise Tax Act and section 25.3 of the Tax Administration Act) RC7257 Third Party Authorization and Cancellation of Authorization for GST/HST and QST Rebates for Selected Listed Financial Institutions RC7259 Business Consent for Certain Selected Listed Financial Institutions RC7259X Cancel Business Consent or Delegated Authority for Certain Selected Listed Financial Institutions RC7260 GST/HST and QST Return for Purchase of Real Property/Immovable or Carbon Emission Allowances by a Selected Listed Financial Institution RC7270 Election or Revocation of an Election to Change a GST/HST and QST Fiscal Year for a Selected Listed Financial Institution RC7271 Notification of Accounting Periods of a Selected Listed Financial Institution for GST/HST and QST RC7291 GST/HST and QST Annual Information Return for Selected Listed Financial Institutions RC7294 GST/HST and QST Final Return for Selected Listed Financial Institutions RC7301 Request for a business number and certain program accounts for certain selected listed financial institutions RC7321 Delegation of Authority for Certain Selected Listed Financial Institutions RC7524-BC GST524 British Columbia Rebate Schedule RC7524-ON GST524 Ontario Rebate Schedule All GST/HST, excise duty and excise taxes and special levies publications can be found on the CRA website. ...