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Specified foreign property includes all of the following: funds or intangible or incorporeal property (patents, copyrights, etc.) situated, deposited, or held outside Canada tangible or corporeal property situated outside Canada a share of the capital stock of a non-resident corporation held by the taxpayer or by an agent on behalf of the taxpayer other than a share of the capital stock of a non-resident corporation that is a foreign affiliate for which you are required to file Form T1134, Information Return Relating to Controlled and Non-Controlled Foreign Affiliates an interest in a non-resident trust that was acquired for consideration, other than an interest in a non-resident trust that is a foreign affiliate shares of corporations that are residents of Canada held by you or for you outside Canada an interest in a partnership that holds a specified foreign property unless the partnership is required to file Form T1135, Foreign Income Verification Statement an interest in, or right with respect to, an entity that is a non-resident a property that is convertible into, exchangeable for, or confers a right to acquire a property that is specified foreign property a debt owed by a non-resident, including government and corporate bonds, debentures, mortgages, and notes receivable precious metals, gold certificates, and futures contracts held outside Canada Specified foreign property does not include any of the following: an interest in your registered retirement savings plan (RRSP), pooled registered pension plan (PRPP), registered retirement income fund (RRIF), registered pension plan (RPP), or tax-free savings account (TFSA) foreign investments held in Canadian mutual funds property used or held exclusively in the course of carrying on your active business your personal-use property Note You have to file Form T1135 for 2022 no later than April 30, 2023, (June 15, 2023, if you or your cohabiting spouse or common-law partner carried on a business in 2021, other than a business whose expenditures are primarily made in the course of a tax shelter investment). ...

Foreign property Specified foreign property includes all of the following: funds or intangible or incorporeal property (patents, copyrights, etc.) situated, deposited, or held outside Canada tangible or corporeal property situated outside Canada a share of the capital stock of a non-resident corporation held by the taxpayer or by an agent on behalf of the taxpayer other than a share of the capital stock of a non-resident corporation that is a foreign affiliate for which you are required to file Form T1134, Information Return Relating to Controlled and Non-Controlled Foreign Affiliates an interest in a non-resident trust that was acquired for consideration, other than an interest in a non-resident trust that is a foreign affiliate shares of corporations that are residents of Canada held by you or for you outside Canada an interest in a partnership that holds a specified foreign property unless the partnership is required to file Form T1135, Foreign Income Verification Statement an interest in, or right with respect to, an entity that is a non-resident a property that is convertible into, exchangeable for, or confers a right to acquire a property that is specified foreign property a debt owed by a non-resident, including government and corporate bonds, debentures, mortgages, and notes receivable precious metals, gold certificates, and futures contracts held outside Canada Specified foreign property does not include any of the following: an interest in your registered retirement savings plan (RRSP), pooled registered pension plan (PRPP), registered retirement income fund (RRIF), registered pension plan (RPP), or tax-free savings account (TFSA) foreign investments held in Canadian mutual funds property used or held exclusively in the course of carrying on your active business your personal-use property Note You have to file Form T1135 for 2022 no later than April 30, 2023, (June 15, 2023, if you or your cohabiting spouse or common-law partner carried on a business in 2022, other than a business whose expenditures are primarily made in the course of a tax shelter investment). ...

When an audit is being conducted, it is advisable for a charity to make all relevant documents available for consideration. ...

The Agency has also been exchanging advanced income tax rulings; those we receive are given consideration as we work to identify new tax schemes and potential non-compliance in Canada. ...

Alignment with the priorities outlined in the Corporate Risk Profile is one of the considerations used to inform the priority ranking of initiatives. ...

Certain services received on a without charge basis, including inter-entity transfers of tangible capital assets for nominal or no consideration, are recorded for departmental financial statement purposes at the carrying amount. ...

Certain services received on a without charge basis, including inter-entity transfers of tangible capital assets for nominal or no consideration, are recorded for departmental financial statement purposes at the carrying amount. ...

Certain services received on a without charge basis, including inter-entity transfers of tangible capital assets for nominal or no consideration, are recorded for departmental financial statement purposes at the carrying amount. ...

Certain services received on a without charge basis, including inter-entity transfers of tangible capital assets for nominal or no consideration, are recorded for departmental financial statement purposes at the carrying amount. ...

Given all of these considerations, competing priorities have impacted the directorate’s ability to respond to external interpretations via a taxpayer’s submission as they have become the least prioritized service. ...