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However, this subparagraph will only apply if the taxpayer settles or extinguishes all debt obligations for consideration that does not include any unit, interest, share, or debt obligation of: (a) the taxpayer; (b) any person with whom the taxpayer does not deal at arm's length; or (c) any partnership or trust of which the taxpayer or a person described in (b) above is a member or beneficiary. ... Subsection 18(9.1) deals with the deductibility of fees paid to a person or partnership to reduce the interest rate on a debt obligation, or as penalties or bonuses in consideration for the repayment of all or a portion of a debt obligation prior to its maturity. ... However, subsection 18(9.1) does not apply to any fee, penalty, or bonus that: may reasonably be considered to have been paid for the extension of the term of a debt obligation or as consideration for the substitution or the conversion of a debt obligation into another debt obligation or into a share; is contingent or dependent upon the use of, or production from, property; is computed by reference to revenue, profit cash flow, commodity price, or any similar criterion; or is computed by reference to any dividends paid or payable on any class of shares in a corporation. ...

In addition, the Agency promotes a portfolio approach to managing investment projects, and risk consideration is one of the key factors required in establishing a CRA investment portfolio. ... The Program Evaluation Plan is based on a number of considerations, including CRA priorities, corporate risks, suggestions from CRA senior management, Treasury Board of Canada Secretariat requirements for evaluations, and Resource and Investment Management Committee (RIMC) requirements. ... Continued to integrate SD considerations into CRA policy instruments. ...

Learning and awareness: Commitment to SD appears in 100% (80) of senior manager (EX/SM) performance expectations and accountability agreements. 100% of RMT members recommended and supported development and implementation of local SD programs; SD leads identified at all responsibility centres SD Lens developed by HQ and distributed to regions in the third quarter of 2003-2004; all SD leads (15) provided with lens to help advise senior managers on integrating SD into business plans and proposals; SD appears as SMT standing agenda item at 75% of responsibility centres SD awareness presentation delivered to 95% of SOR senior managers SD considerations have been integrated into regional procurement training (WEBRO, WHMIS), new employee orientation packages, and local IT end-user training, and has appeared in employee information packages developed in support of major renovation and construction projects (Hamilton and St. ... The Materiel Management Directorate (MMD) updated the procurement certification program to include environmental considerations and green content. ... Information Technology Best practices: Used the Green Move Protocol to relocate staff to new IT campuses throughout the year Incorporated SD considerations into branch procurement of IT hardware, printers/ photocopiers (duplex-capable), and energy efficient monitors; recycled toner cartridges, diskettes, and CDs Reduced the number of printers, photocopiers, and fax machines on each floor to conserve energy and paper use (for example, the branch now has a ratio of 40 employees to 1 printer) Learning and awareness: Hosted regular lunch and learn session on various SD topics Promoted SD and wellness to employees through information provided on the branch Wellness Web site As an employees SD awareness activity, the branch collected 470 disposable cups in two days from five floors of the Fitzgerald Campus, and used the cups to make a Paper Cup Man to display in the foyer of the campus. ...

Much of the Future-oriented Statement of Operations is based on these assumptions, best estimates, and judgment and gives due consideration to materiality. ... Yes (March 31, 2015) GHG emissions (CO2 equivalent) in fiscal year 2005-2006. 403 tonnes GHG emissions (CO2 equivalent) in current fiscal year. 318 tonnes Percentage change in GHG emissions from fiscal year 2005-2006 to the current fiscal year-21% Goal: Waste and asset management Target: Green procurement As of April 1, 2014, the CRA will continue to take action to embed environmental considerations into Crown procurement. ... Targeted performance level: Seeking to reach "Achieved" Implementation strategy element: Integrate environmental considerations into corporate policies, processes, and practices in accordance with departmental refresh cycles. ...

When determining if land that is capital real property of an individual or personal trust is used primarily in a business rather than primarily in non-business uses immediately prior to its sale, consideration must be given to all uses of the land throughout the time it is owned by the individual or personal trust. 4. ... However, consideration should be given to possibility of section 196.1 applying in such circumstances Footnote 17. ... Footnotes Footnote 15 In the absence of legal restrictions such as minimum lot size or functional considerations such as needing additional land for road access, the amount of land considered to form part of the residential complex, i.e., the amount of land considered to be reasonably necessary for the use and enjoyment of the residential unit as a place of residence, would be restricted to a half hectare. ...

Election to not account for GST/HST on actual taxable supplies Effective for supplies made after March 21, 2013, the budget proposes to allow a participating employer of a pension plan and a pension entity of the pension plan to make a joint election to treat an actual taxable supply of property or a service by the employer to the pension entity as being made for no consideration where the employer accounts for and remits tax on the deemed supply of the property or service or on the consumption or use of inputs for the purpose of making the actual supply. ... Relief from accounting for tax on deemed taxable supplies Effective for fiscal years of an employer beginning after March 21, 2013, the budget also proposes that: A participating employer of a pension plan would be fully relieved from applying the deemed taxable supply rules in respect of the pension plan for a fiscal year where: an election with a pension entity of the pension plan to treat actual taxable supplies as being made for no consideration (discussed above) is not in effect for the employer; and the amount of the GST (including the federal part of the HST) that the employer was (or would have been, but for this measure) required to account for and remit under the deemed supply rules in respect of the pension plan in its preceding fiscal year is both less than $5,000 and less than 10% of the total net GST (including the federal part of the HST) paid by all pension entities of that pension plan in that preceding fiscal year. ... An employer that is entitled to relief under this provision would also be able to treat its actual taxable supplies as being for no consideration where the election, discussed above, is in effect. ...

The set on-call fee that is paid in respect of this on-call coverage would be consideration for this taxable supply. Additional amounts paid to compensate the medical practitioner for their intervention in patient care would generally be viewed as consideration for an exempt supply, as that intervention would generally qualify as an exempt supply of a health care service under section 5 of Part II of Schedule V. ... It should also be noted that if the consideration for the supply of the right to call upon the medical practitioner is payable or reimbursed by the government of a province, under a plan established under an act of the legislature of the province to provide for health care services for all insured persons of the province, the supply of the right may be an exempt supply of property under section 9 of Part II of Schedule V. ...

In cases where one of the main purposes of a person's absence from Canada is to avoid Canadian taxes, which would otherwise be payable, consideration may be given to other factors in determining the person's residence status. ... However, because each province has its own guidelines and policy regarding eligibility for benefits after leaving Canada, continuing coverage under a provincial plan will not be considered to be a significant residential tie, but will be given consideration when reviewing all the facts.) the registration of property that is being taken outside Canada with Canada Customs; the rental of a safety deposit box or postal box in Canada; the listing of a telephone number in a telephone directory in Canada; the continued use of stationery and business cards with a Canadian address; and professional or other memberships in Canada (on a resident basis). 25. ... The value of consideration for these supplies is deemed to be the fair market value of the supply at the time the property is transferred or the service is rendered. ...

In the future, consideration may be given to expanding the scope of the program to include individuals who prepare other types of tax returns such as income tax returns for trusts (Form T3, Trust Income Tax and Information Return), and GST/HST returns. ... Consideration is being given to publishing a list of registered tax preparers. ... While they have been designed in consideration of the needs of third parties and are available to tax preparers, they have not been designed to exclusively address the needs of tax preparers. ...

In addition, the Agency promotes a portfolio approach to managing investment projects, and risk consideration is one of the key factors required in establishing a CRA investment portfolio. ... The Program Evaluation Plan is based on a number of considerations, including CRA priorities, corporate risks, suggestions from CRA senior management, Treasury Board of Canada Secretariat requirements for evaluations, and Resource and Investment Management Committee (RIMC) requirements. ... Continued to integrate SD considerations into CRA policy instruments. ...