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Specific Situations Not Accepted for Canadian Competent Authority Consideration 26. ... The Canadian Competent Authority will give due consideration to the findings made by the Appeals Branch with regard to the application of Canadian law. 42. ... Provincial Income Tax Considerations 59. The provinces and territories are not bound by Canadian tax conventions. ...

Specific Situations Not Accepted for Canadian Competent Authority Consideration 26. ... The Canadian Competent Authority will give due consideration to the findings made by the Appeals Branch with regard to the application of Canadian law. 42. ... Provincial Income Tax Considerations 59. The provinces and territories are not bound by Canadian tax conventions. ...

Refer to Appendix A.6 for a discussion of some specific considerations for dealing with files where there is a NOO or appeal, and when the RTA may be involved in the appeals review process. ... Chapter 5.11.3 discusses procedures for dealing with problems of inadequate records and books. 2.9.0 Contact and communications with the claimant 2.9.1 General considerations All RTAs must know and follow the CRA policy on communications security for protected information. ... The RTA must take into consideration the CRA service standards when planning and conducting a review. ...

This is an important consideration for demonstrating the extent to which the issues were communicated to the claimant by the FR, and the efforts to work with the claimant to resolve these issues. ... The FR needs to take into consideration the CRA service standards when planning and conducting a review. ... Consideration of penalties must be discussed with the FRM in all cases. ...

Income tax considerations The following sections outline the income tax implications of common transactions involving crypto-assets. ... GST/HST considerations Based on your cryptoasset activities, you may have to register for and start charging the GST/HST. ... The calculation excludes consideration attributable to the sale of goodwill of a business, supplies of financial services, and supplies by way of sale of capital property. ...

Income tax considerations The following sections outline the income tax implications of common transactions involving crypto-assets. ... GST/HST considerations Based on your cryptoasset activities, you may have to register for and start charging the GST/HST. ... The calculation excludes consideration attributable to the sale of goodwill of a business, supplies of financial services, and supplies by way of sale of capital property. ...

Lease intervals – Deemed supplies of real property Where a supply of property is made by way of lease, license or similar arrangement for consideration that is attributable to a period (referred to as a "lease interval") that is the whole or a part of the period during which possession or use of the property is provided under the arrangement, a separate supply of the property for separate consideration is deemed to be made by the supplier and received by the recipient for each lease interval. ... Examples- When the province in which the greatest proportion of the Canadian rights can be used cannot be determined Example 1- Consideration of $300 or less An individual purchases a movie pass that provides ten adult admissions to any of a movie chain's five cinemas situated in Nova Scotia and New Brunswick. ... Examples- When the supply can be used otherwise than only primarily in participating provinces or non-participating provinces Example 1- Consideration of $300 or less An individual purchases a movie pass that provides ten adult admissions to any of a popular movie chain's locations. ...

Nominal consideration 21. Subsection 141.01(1.1) provides that, for purposes of determining the extent of use in subsections 141.01(1.2) to (3), supplies for nominal consideration are treated the same as supplies for no consideration. The term “nominal consideration” is not defined in the Act. A determination of whether a supply is made for nominal consideration will be based on the facts of the individual case. ... For example, under subsection 153(1), where the consideration or a part of the consideration is expressed in money, the value of the consideration or that part is deemed to be equal to the amount of the money and, where the consideration or part is other than money, the value of the consideration or that part is deemed to be equal to the fair market value of the consideration or that part at the time the supply was made. 23. ...

Nominal consideration 21. Subsection 141.01(1.1) provides that, for purposes of determining the extent of use in subsections 141.01(1.2) to (3), supplies for nominal consideration are treated the same as supplies for no consideration. The term “nominal consideration” is not defined in the Act. A determination of whether a supply is made for nominal consideration will be based on the facts of the individual case. ... For example, under subsection 153(1), where the consideration or a part of the consideration is expressed in money, the value of the consideration or that part is deemed to be equal to the amount of the money and, where the consideration or part is other than money, the value of the consideration or that part is deemed to be equal to the fair market value of the consideration or that part at the time the supply was made. 23. ...

This will be the taxpayer's only opportunity to submit additional information for the TPRC's consideration. ... Recharacterization referrals In situations involving the application of paragraphs 247(2)(b) and (d), the TPRC uses a three-stage approach: Initial consideration Consideration of a formal referral Final consideration 1. ... The taxpayer should be encouraged to bring forward facts for consideration during the review. 2. ...