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GST/HST Ruling

8 March 2011 GST/HST Ruling 118705 - Entitlement to 83% Rebate - [Corporation A]

It would seem to follow that consideration of legislative purpose may not only resolve patent ambiguity, but may, on occasion, reveal ambiguity in apparently plain language. ...
Current CRA website

Canada Revenue Agency Annual Report to Parliament 2013-2014

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

2019 First Annual Report of the Disability Advisory Committee: Enabling access to disability tax measures – Report in brief

A diagnosis would not be the primary consideration in determining eligibility, but it could provide more context to strengthen a case for coverage. ...
Current CRA website

Completing your return (Steps 1 and 2)

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 of 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 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 an interest in a foreign insurance policy precious metals, gold certificates, and futures contracts held outside Canada Specified foreign property does not include any of the following: property in your registered retirement savings plan (RRSP), pooled registered pension plan, registered retirement income fund, registered pension plan, or tax-free savings account 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 2021 no later than April 30, 2022, (June 15, 2022, 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). ...
Archived CRA website

ARCHIVED - Identification and other information, and total income

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 of 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 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 an interest in a foreign insurance policy precious metals, gold certificates, and futures contracts held outside Canada Specified foreign property does not include any of the following: property 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 you 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 2020 no later than April 30, 2021, (or June 15, 2021, if you or your cohabiting spouse or common-law partner carried on a business in 2020, other than a business whose expenditures are primarily made in the course of a tax shelter investment). ...
Current CRA website

and Deemed Residents of Canada – Completing your return: Steps 1 and 2

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). ...
Archived CRA website

ARCHIVED - Identification and other information, and total income

Specified foreign property includes all of the following: funds or intangible property (patents, copyrights, etc.) situated, deposited or held outside Canada tangible property situated outside of 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 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 resident in 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 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 an interest in a foreign insurance policy precious metals, gold certificates, and futures contracts held outside Canada Specified foreign property does not include any of the following: property 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 you used or held exclusively in the course of carrying on your active business your personal-use property For more information on specified foreign property, see Form T1135, Foreign Income Verification Statement. ...
Current CRA website

Evaluation – Income Tax Rulings Directorate

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. ...
Current CRA website

Annual report to parliament 2012–2013

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

Canada Revenue Agency Financial Statements – Agency Activities

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. ...

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