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If a Ruling request is subsequently submitted by the taxpayer, the hourly fee charged for the Ruling will take into consideration the hours spent on the Pre-ruling Consultation. ... FROM: [Name and address of taxpayer] RE: [Brief description of the advance income tax ruling (Ruling) request] IN CONSIDERATION of the Canada Revenue Agency (CRA) agreeing to examine a request for an advance income tax ruling and any supplemental ruling (together the “Ruling request”), the undersigned taxpayer hereby undertakes: To remit to the CRA, within 30 days of receipt of written demand, any and all fees payable to the CRA with respect to the above noted Ruling request, irrespective of whether the ruling has been issued, which fees are prescribed under the Advance Income Tax Ruling Fees Order, SOR/90-234. ... FROM: [Name and address of representative’s firm] RE: [Name of taxpayer and brief description of the advance income tax ruling request] IN CONSIDERATION of the Canada Revenue Agency (CRA) agreeing to examine a request for an advance income tax ruling and any supplemental ruling (together the Ruling request) in which the firm is involved, the undersigned firm hereby undertakes: To remit to the CRA, within 30 days of receipt of written demand, any and all fees payable to the CRA with respect to the above noted Ruling request, irrespective of whether the ruling has been issued, which fees are prescribed under the Advance Income Tax Ruling Fees Order, SOR/90-234. ...

A person who makes a supply for consideration greater than the expenses involved in making the supply has a profit, but he/she will still not have a commercial activity unless the supply comes within paragraphs (a), (b) or (c) of the definition of commercial activity. ... In applying this factor, external influences such as economic conditions, changes in the public mood, etc., which may affect the sale of artistic or literary works will be taken into consideration; and The nature of the literary works undertaken by a writer. ... However, where a person first establishing such an activity applies for registration, there will not be a history of profit or loss in previous years available for consideration. ...

If a Ruling request is subsequently submitted by the taxpayer, the hourly fee charged for the Ruling will take into consideration the hours spent on the Pre-ruling Consultation. ... FROM: [Name and address of taxpayer] RE: [Brief description of the advance income tax ruling (Ruling) request] IN CONSIDERATION of the Canada Revenue Agency (CRA) agreeing to examine a request for an advance income tax ruling and any supplemental ruling (together the “Ruling request”), the undersigned taxpayer hereby undertakes: To remit to the CRA, within 30 days of receipt of written demand, any and all fees payable to the CRA with respect to the above noted Ruling request, irrespective of whether the ruling has been issued, which fees are prescribed under the Advance Income Tax Ruling Fees Order, SOR/90-234. ... FROM: [Name and address of representative’s firm] RE: [Name of taxpayer and brief description of the advance income tax ruling request] IN CONSIDERATION of the Canada Revenue Agency (CRA) agreeing to examine a request for an advance income tax ruling and any supplemental ruling (together the Ruling request) in which the firm is involved, the undersigned firm hereby undertakes: To remit to the CRA, within 30 days of receipt of written demand, any and all fees payable to the CRA with respect to the above noted Ruling request, irrespective of whether the ruling has been issued, which fees are prescribed under the Advance Income Tax Ruling Fees Order, SOR/90-234. ...

A person who makes a supply for consideration greater than the expenses involved in making the supply has a profit, but he/she will still not have a commercial activity unless the supply comes within paragraphs (a), (b) or (c) of the definition of commercial activity. ... In applying this factor, external influences such as economic conditions, changes in the public mood, etc., which may affect the sale of artistic or literary works will be taken into consideration; and The nature of the literary works undertaken by a writer. ... However, where a person first establishing such an activity applies for registration, there will not be a history of profit or loss in previous years available for consideration. ...

This information circular provides general guidelines on some of the relevant considerations in the exercise of this discretion. ... Given the complexity of transfer pricing issues, applications relating to transfer pricing matters will be referred to the Transfer Pricing Review Committee for their consideration under subsection 220(3.1). ... If it is discovered during the course of the review that the taxpayer had previously made an application, the CRA may refuse to give the second application further consideration under the VDP. 27. ...

We envision that we can use our service provider role to influence and strengthen the inclusion of social, economic, environmental, and good governance considerations in these processes. ... The criteria are presented as a checklist of questions under the headings of social, economic, environment, and good governance considerations. ... [Footnote 13] The Relocation Policy was not slated for review; hence no work ensued, given the agreed best practice of integrating SD considerations during policy/program review and update. ...

Supplies made on lands where an FNGST applies Where taxable supplies of property and services are made on the lands of a First Nation that has imposed an FNGST, the FNGST is calculated by multiplying the consideration for the supply by 5%. ... The dealer charges the FNGST on the consideration for the rental of the video camera because it was made available to the person on the lands where the FNGST applies. ... Non‑registrants are required to use Form GST59, GST/HST Return for Imported Taxable Supplies, Qualifying Consideration, and Internal and External Charges to report FNGST, and the provincial part of the HST where applicable. ...

This information circular provides general guidelines on some of the relevant considerations in the exercise of this discretion. ... Given the complexity of transfer pricing issues, applications relating to transfer pricing matters will be referred to the Transfer Pricing Review Committee for their consideration under subsection 220(3.1). ... If it is discovered during the course of the review that the taxpayer had previously made an application, the CRA may refuse to give the second application further consideration under the VDP. 27. ...

Footnote 5 For example, the applicant organization must be able to show that particular sport activities are chosen with the charitable purposes and public benefit as primary considerations. ... A determination of whether an organization's purpose is charitable will be made by taking into account the following considerations: the proportion of the organization's expenditures related to activities open to all levels of skill relative to the expenditures related to elite competitive sport activities the number of people participating in activities open to all levels of skill relative to the number of people participating in elite competitive sport activities the amount of financial support for elite competitive athletes and the relative amount of resources allocated to them in excess of the basic or average amount of resources allocated to other participants whether the organization presents itself as primarily providing activities open to everyone served by the charity's programs, regardless of their level of ability, and conducts outreach to recruit participants regardless of level of skill 5. ... To do so, it will have to show that the limitation to the particular sport: is reasonable, as opposed to arbitrary, considering the nature of the recognized charitable purpose it intends to further Footnote 25 will not deter or exclude a substantial proportion of those that could be served by the charity is the most practical use of the charity's resources, at least as a starting point, for reasons such as expertise, effectiveness, and financial consideration Organizations that meet the criteria for registration outlined in this policy can apply for charitable status by going to Apply to become a registered charity. ...

This memorandum provides general guidelines on some of the relevant considerations in the exercise of this discretion. ... If it is discovered during the course of the review that the registrant had previously made an application, the CRA may refuse to give the second application further consideration under the VDP. 65. ... If a registrant’s VDP application is accepted under Category 3 (the Limited Program), in consideration of the relief being provided, the registrant will be required to waive their rights to object and appeal in relation to the specific matter disclosed in the VDP application and any specifically related assessment of taxes. ...