Search - consideration

Financial Claim Review Manual – Review procedures for financial reviewers SR&ED Program Previous chapter Table of contents Next chapter Chapter 6.0 Finalizing the Review Table of contents 6.1 Summary of chapter 6.2 Requirements of the chapter 6.3 Introduction 6.4 Reports to document the results of the review 6.4.1 The SR&ED financial review report 6.4.1.1 Contents of the SR&ED financial review report 6.4.2 Short SR&ED financial review report 6.4.3 Penalty recommendation report 6.4.4 Taxpayer relief (fairness) report 6.4.5 Documentation for Headquarters 6.5 Forms for finalizing an SR&ED claim review 6.5.1 T7W-9 and T7W-C 6.5.1.1 Amalgamations 6.5.1.2 Non-capital loss application on T7W-9 6.5.2 T99A- T2 Tax Calculation Information Sheet 6.5.2.1 Area A – Multiple jurisdictions 6.5.2.2 Area B – Calculation of taxable income – Loss carryback 6.5.2.3 Area C – Changes in investment income and income from active business 6.5.2.4 Area D – Small business deduction 6.5.2.5 Area E – Manufacturing and processing profits deduction 6.5.2.6 Area F – Part IV Tax (private and subject public corporation at any time during the year) 6.5.2.7 Area G – Dividend refund 6.5.2.8 Area H – Surtax credit (1992 and subsequent years) 6.5.2.9 Area I – Federal investment tax credit (Subsection 127(5) of the Act) 6.5.2.10 Area J – Section 163 penalties 6.5.2.11 Area K – Appeal 6.5.3 Revised schedules 6.6 Audit Information Management System 6.7 Assessments 6.7.1 Legislative authority 6.7.2 Normal reassessment period (statute-barred date) 6.7.3 Nil assessment – Notification 6.8 Loss determination 6.8.1 Loss determination statement 6.9 T2 Corporation Income Tax Returns approaching the statute-barred date 6.9.1 Processing procedures 6.10 Preassessment refund 6.11 Loss carryback administrative procedures 6.12 Revision of capital cost allowance, SR&ED expenditures and other permissive deductions 6.13 Retention of hard copy (paper) documents 6.14 Permanent documents 6.15 Indexing and organization of working papers 6.15.1 Indexing and cross-referencing 6.16 Additional considerations for large files 6.17 Checklist for the assembly of the SR&ED review file 6.18 Assembling the file for (re)assessing 6.19 Processing the SR&ED File This is a message which indicates that the Claim Review Manual for SR&ED financial reviewers is now effective and that the public severed version is available. 6.1 Summary of chapter This chapter discusses the procedures for finalizing the review. The main topics of this chapter are: 6.2 Requirements of the chapter 6.3 Introduction 6.4 Reports to document the results of the review 6.5 Forms for finalizing an SR&ED claim review 6.6 Audit Information Management System 6.7 Assessments 6.8 Loss determination 6.9 T2 Corporation Income Tax Returns approaching the statute-barred date 6.10 Preassessment refund 6.11 Loss carryback administrative procedures 6.12 Revision of capital cost allowance, SR&ED expenditures and other permissive deductions 6.13 Retention of hard copy (paper) documents 6.14 Permanent documents 6.15 Indexing and organization of working papers 6.16 Additional considerations for large files 6.17 Checklist for the assembling of the SR&ED review file 6.18 Assembling the file for (re)assessing 6.2 Requirements of the chapter This chapter outlines what is required to finalize the SR&ED review. ... Refer to Chapter 5.10.2 for details. 6.16 Additional considerations for large files Once again the FR should consult with the LFCM to determine if the SR&ED adjustments will be assessed independently or concurrently with the adjustments of other audit functions. ...

Financial Claim Review Manual – Review procedures for financial reviewers SR&ED Program Previous chapter Table of contents Next chapter Chapter 6.0 Finalizing the Review Table of contents 6.1 Summary of chapter 6.2 Requirements of the chapter 6.3 Introduction 6.4 Reports to document the results of the review 6.4.1 The SR&ED financial review report 6.4.1.1 Contents of the SR&ED financial review report 6.4.2 Short SR&ED financial review report 6.4.3 Penalty recommendation report 6.4.4 Taxpayer relief (fairness) report 6.4.5 Documentation for Headquarters 6.5 Forms for finalizing an SR&ED claim review 6.5.1 T7W-9 and T7W-C 6.5.1.1 Amalgamations 6.5.1.2 Non-capital loss application on T7W-9 6.5.2 T99A- T2 Tax Calculation Information Sheet 6.5.2.1 Area A – Multiple jurisdictions 6.5.2.2 Area B – Calculation of taxable income – Loss carryback 6.5.2.3 Area C – Changes in investment income and income from active business 6.5.2.4 Area D – Small business deduction 6.5.2.5 Area E – Manufacturing and processing profits deduction 6.5.2.6 Area F – Part IV Tax (private and subject public corporation at any time during the year) 6.5.2.7 Area G – Dividend refund 6.5.2.8 Area H – Surtax credit (1992 and subsequent years) 6.5.2.9 Area I – Federal investment tax credit (Subsection 127(5) of the Act) 6.5.2.10 Area J – Section 163 penalties 6.5.2.11 Area K – Appeal 6.5.3 Revised schedules 6.6 Audit Information Management System 6.7 Assessments 6.7.1 Legislative authority 6.7.2 Normal reassessment period (statute-barred date) 6.7.3 Nil assessment – Notification 6.8 Loss determination 6.8.1 Loss determination statement 6.9 T2 Corporation Income Tax Returns approaching the statute-barred date 6.9.1 Processing procedures 6.10 Preassessment refund 6.11 Loss carryback administrative procedures 6.12 Revision of capital cost allowance, SR&ED expenditures and other permissive deductions 6.13 Retention of hard copy (paper) documents 6.14 Permanent documents 6.15 Indexing and organization of working papers 6.15.1 Indexing and cross-referencing 6.16 Additional considerations for large files 6.17 Checklist for the assembly of the SR&ED review file 6.18 Assembling the file for (re)assessing 6.19 Processing the SR&ED File This is a message which indicates that the Claim Review Manual for SR&ED financial reviewers is now effective and that the public severed version is available. 6.1 Summary of chapter This chapter discusses the procedures for finalizing the review. The main topics of this chapter are: 6.2 Requirements of the chapter 6.3 Introduction 6.4 Reports to document the results of the review 6.5 Forms for finalizing an SR&ED claim review 6.6 Audit Information Management System 6.7 Assessments 6.8 Loss determination 6.9 T2 Corporation Income Tax Returns approaching the statute-barred date 6.10 Preassessment refund 6.11 Loss carryback administrative procedures 6.12 Revision of capital cost allowance, SR&ED expenditures and other permissive deductions 6.13 Retention of hard copy (paper) documents 6.14 Permanent documents 6.15 Indexing and organization of working papers 6.16 Additional considerations for large files 6.17 Checklist for the assembling of the SR&ED review file 6.18 Assembling the file for (re)assessing 6.2 Requirements of the chapter This chapter outlines what is required to finalize the SR&ED review. ... Refer to Chapter 5.10.2 for details. 6.16 Additional considerations for large files Once again the FR should consult with the LFCM to determine if the SR&ED adjustments will be assessed independently or concurrently with the adjustments of other audit functions. ...

For example, the entity could hold assets for a customer of a related entity, or consideration is paid to a related entity, either as an identifiable payment or as one element of a consolidated payment. ... Other considerations 10.78 A Canadian financial institution may receive a self-certification from an entity that is not resident in Canada that it is a financial institution. ... If this is an important consideration for a financial institution in connection with its initial transition to the Part XVIII regime, it can act accordingly so long as there is no delay of more than six calendar days, the transition procedure is documented, and the purposes of the Agreement are not frustrated by any such scheduling. ...

These are calculated by reference to a specified index upon a notional principal amount in exchange for specified consideration or a promise to pay similar amounts.); an insurance contract or an annuity contract; and any option or other derivative instrument. 6.28 Insurance contracts and annuity contracts are not considered to be custodial accounts. ... Other considerations 10.60 A Canadian financial institution may receive a self-certification from an entity that is not resident in Canada that it is a financial institution. ... If this is an important consideration for a financial institution in connection with its initial transition to the Part XVIII regime, it can act accordingly so long as there is no delay of more than six calendar days, the transition procedure is documented, and the purposes of the Agreement are not frustrated by any such scheduling. ...

Consideration must be given to any purpose or function for which the entity is licensed or regulated (including those of any predecessor). 3.11 There can be circumstances where an entity holds financial assets for a customer where the income attributable to holding the financial assets or providing related financial services belongs to (or is otherwise paid to) a related entity. For example, the entity could hold assets for a customer of a related entity, or consideration is paid to a related entity, either as an identifiable payment or as one element of a consolidated payment. ... Other considerations 9.83 A Canadian financial institution may receive a self-certification from an entity that is not resident in Canada that it is a financial institution. ...

The consideration is paid without having become due when a recipient pays all or part of the consideration for a supply before the amount becomes due. ... Where the consideration for a taxable supply is paid or becomes due on more than one day, the HST becomes payable on the day that is the earlier of the day that part of the consideration is paid and the day that part of the consideration becomes due. ... When is the consideration paid without having become due? The consideration is paid without having become due when a recipient pays all or part of the consideration for a supply before the amount becomes due. ...