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(i) To the extent that the MAP cases currently being negotiated cover taxation years that precede the 2020 COVID-19 crisis, the CRA does not envision any impacts on these cases or the need to adopt special considerations on account of the COVID-19 crisis. ... CRA Response (A)(i) MAP cases that are currently being negotiated To the extent that the MAP cases currently being negotiated cover taxation years that precede the 2020 COVID-19 crisis, the CRA does not envision any impacts on these cases or the need to adopt special considerations on account of the COVID-19 crisis. ...

X exchange their common shares of the capital stock of the corporation in consideration for preferred shares of the capital stock of the corporation pursuant to subsection 51(1). ... X) then each subscribe for an equal number of new common shares of the capital stock of the corporation for nominal consideration. ...

Accordingly, consideration could be given to deleting the reference here to class 12.       ... Could consideration be given to choosing some consistent terminology so as not to confuse a reader? ...

Consequently, although CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee.  ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year.  ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, those CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee.  ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the  trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year.  ...

While number 11 of the proposed Application form indicates that this requirement will be met, we find the third paragraph under the caption "Tax Considerations" to be confusing in this regard and we suggest it be reworded to clearly reflect this requirement. 7.      ... In line three of the last paragraph under the caption "Tax Considerations", we suggest that "employment" be inserted before "income". ...

The Supreme Court was only concerned with the meaning of the word "control", and the trial judge was therefore at liberty to take account of larger considerations than those which were before the Supreme Court.  Those larger considerations would not be relevant in an interpretation of subsection 249(4) of the Act, having regard to the absence of the words "or indirectly in any manner whatever" from that provision. ...

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, those CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee.  ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year.  ...

One consideration may point so clearly that it dominates other and vaguer indications in the contrary direction.  ... While each case is found to turn upon its own facts, and no infallible criterion emerges, nevertheless the decisions are useful as illustrations and as affording indications of the kind of considerations which may relevantly be borne in mind in approaching the problem. ...

In consideration therefore, the Canadian corporation will receive a limited right to resultant know-how in order to permit it to manufacture and market any resultant product of the SR&ED. ... In TR-47, the general point under consideration was whether Part XIII of the Act would apply to payments by a person resident in Canada to a non-resident where those payments represented the Canadian resident's obligations under a research project carried out jointly by the Canadian resident and the non-resident.  ...