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Current CRA website
Treatment of Bare Trusts under the Excise Tax Act
(Black's Law Dictionary) settlor means one who furnishes the consideration for the creation of a trust, though in form the trust is created by another. ... Transfer of Title to and from the Trustee Sections 268 and 269 of the Act provide that where a person settles property in an inter-vivos trust and where the trustee distributes property of the trust to the beneficiaries, the settling or distribution of the property is deemed to be a supply for consideration equal to the amount determined under the Income Tax Act. ...
Current CRA website
The Acceptance of a Due Diligence Defence for a Penalty Imposed Under Subsection 280(1) of the Excise Tax Act for Failure to Remit or Pay an Amount When Required, and for a Penalty Imposed Under Section 280.1 for Failure to File a Return When Required
However, in a case where actions taken by a person’s authorized representative lend support to a person’s due diligence defence, these actions will be taken into consideration in determining whether a person has been duly diligent. ... The registrant makes a request to the CRA to give consideration to cancelling the penalty based on a due diligence defence. ...
Current CRA website
CRA Administrative Positions on the Application of the Import Rules for Financial Institutions to Reinsurance Contracts
For example a qualifying taxpayer is required to self-assess tax on the non-financial (“loading”) part of the consideration for an imported financial service where the parties are not dealing at arm’s length. Loading is defined as that part of the consideration for a financial service that is attributable to administrative expenses, profit and error margins, employee compensation, and other similar amounts. ...
Current CRA website
annual report to parliament 2012-2013
As in the past, the Board continues to carefully balance the interests of the CRA while keeping in mind government wide considerations. ... Commissioner of Revenue and Chief Executive Officer Canada Revenue Agency Ottawa, Ontario [committee membership and director participation] The Board of Management is supported by four committees that undertake much of the detailed review of items brought before the Board for the Board's consideration. ...
Current CRA website
Questions and Answers, Registered Education Savings Plan (RESP) - Consultation Session October 29, 2002
Any such change should be proposed to the Department of Finance for its review and consideration. 3. ... Any such change should be proposed to the Department of Finance for its review and consideration. 4. ...
Current CRA website
SR&ED claims made by physicians and Medical Professional Corporations - Information for claimants
Emails or signed attestations outlining the terms of the SR&ED work to be performed may also be submitted for consideration. ... Considerations Scenario 1: Individual/ Independent Contractor (proprietor unincorporated business) A) Physicians directly undertaking SR&ED work. ...
Current CRA website
Standard Timelines for Information Requests to Taxpayers for Audit Purposes
The deadline for a response to a proposed reassessment ("proposal letter") should take into consideration statute-barred dates and treaty time limits. ... Return to footnote9 referrer Footnote 10 The deadline for a response to a proposed reassessment ("proposal letter") should take into consideration statute-barred dates and treaty time limits. ...
Current CRA website
Financial Claim Review Manual – Review procedures for financial reviewers
Additional considerations for large files are included at or near the end of chapters 4, 5 and 6 to outline the particularities of processing such files, and the procedures for processing partnership claims for SR&ED are included in an appendix. There may be other particularities to take into consideration in processing SR&ED claims from other types of entities such as, individuals, limited partnerships, trusts, joint ventures, and cooperatives, which are not covered in the CRM. ...
Current CRA website
Chapter 20 - 8517 – Transfer – Defined Benefit to Money Purchase
The following conditions must be satisfied for a plan administrator to receive favourable consideration from the CRA: the member is an employee or former employee of the employer; the employer was a participating employer, and is undergoing insolvency proceedings under the Bankruptcy and Insolvency Act or Companies' Creditors Arrangement Act, and has ceased making contributions to the plan; LRBs have been reduced due to the plan’s underfunded status; the plan is not a designated plan; and the Minister has approved the application of subsection 8517(3.01) of the Regulations. ... In the case of an underfunded IPP, similar consideration may be provided as long as the lump-sum amount transferred from the plan represents the final payment from the IPP. ...
Current CRA website
CVITP learning guide walkthrough
Image on screen: Tax considerations for Newcomers and Indigenous Peoples page Narrator: In the Tax considerations for Newcomers and Indigenous peoples section [callout surrounds the section and cursor clicks on the link], you’ll find additional information related to these specific clienteles as they often have unique tax filing requirements. ...