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Roth Individual Retirement Accounts (Roth IRAs), contact us at: International and Large Business Directorate Competent Authority Services Division 344 Slater Street 18th Floor, Canada Building Ottawa ON K1A 0L5 email: CPMAPAPAG@cra-arc.gc.ca Office of the Director – Competent Authority Services Division Jennings, Michael – Director, 343-551-1343 Mutual Agreement Procedure – Advance Pricing Arrangement Section 1: Paul, Jennifer – Manager, 438-337-5823 Section 2: Nemeth, Jaime – Manager, 416-458-2173 Section 3: McSpaden, Chuck – Manager, 873-455-2832 Section 4: Zappavigna, Antonio – Manager, 343-551-9002 Mutual Agreement Procedure – Technical Cases Tarres, Ana-Maria – Manager, 819-775-2194 For more information concerning the application of tax treaties where specific taxpayers are not involved, non-discrimination, recognition of foreign pension plans under treaties, and consideration of requests under paragraph 6, of Article XXIX A (Limitation on Benefits) in the Canada-US Tax Convention, contact us at: Competent Authority Policy and Treaty Advisory Section International Relations and Treaties Office Legislative Policy Directorate Legislative Policy and Regulatory Affairs Branch 6th Floor, Tower A Place de Ville 320 Queen Street Ottawa ON K1A 0L5 Email: CA.IRTO-AC.BRCI@cra-arc.gc.ca Acting Director Page details Date modified: 2024-06-26 ...

The person with the lower salary should then take into consideration the clergy residence deduction made by the person with the higher salary, and also include any other deduction for the same accommodation. ...

The CRA will take into consideration the specific facts of each case, and will exercise this discretionary authority in a fair and judicious manner. ...

CRA staff then provided an update to the DAC on the Accessibility file, including roles and responsibilities to deliver on the Agency’s obligations under the Accessible Canada Act, research, public consultations and engagement to date, and discussion questions for consideration by Committee members. ...

Indigenous Issues: Members noted that consideration should be given to expand the list of approved health practitioners who can submit the DTC application to address the limited access to health providers in some Indigenous communities. ...

Definitions Amount of advantage: The total value of all property, services, compensation or other benefits to which the donor of a property, or a person not dealing at arm's length with the donor, is entitled as partial consideration for, or in gratitude for, the gift. ...

These themes were identified taking into consideration the various backgrounds and expertise of the members, the recommendations outlined in the report from the Special Senate Committee on the Charitable Sector and the importance of fostering accountability and transparency. ...

Specifically, they discussed opportunities to improve the CRA’s service role for charities, the balance of fairness with compliance, and topics identified by the Senate Committee that were referred to the ACCS for consideration. ...

In urgent circumstances, the CRA will expedite consideration of these applications. ...

When the loanback provisions apply, the qualified donee that receives the gift should reduce the amount that would otherwise be reported on the official receipt that it may issue, according to the two possible situations as follows: Situation one: the fair market value of the gift is reduced by the fair market value of the consideration given by the qualified donee for the non-qualifying security Situation two: the fair market value of the gift is reduced by the fair market value of the qualified donee's property that was used When the loanback provisions take effect after the qualified donee issues a receipt for income tax purposes, the qualified donee should issue a revised receipt to reflect the fair market value as adjusted by the provisions described above. ...