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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. ...