Search - consideration

. ¶1.9 (formerly included in ¶5 of IT-270R3) now includes a reference to documentary or stamp taxes in the examples of items not considered to be income or profits taxes in consideration of the CRA’s position on the general nature of these taxes. ¶1.10 (formerly included in ¶5 of IT-270R3) has been revised to change business income to net business income in the first sentence for greater clarity. ¶1.16 (formerly included in ¶7 of IT-270R3) now includes an example describing a taxpayer with different taxing and business countries. ¶1.25 (formerly included in ¶8 of IT-270R3) has been reworded to remove ambiguity as to whether foreign was meant to describe the other person or partnership and to better reflect paragraph (e) of the definition of non-business-income tax in subsection 126(7). ¶1.26 (formerly included in ¶8 of IT-270R3) now includes a reference to the amendments to the overseas employment tax credit contained in the Jobs and Growth Act, 2012; edited to remove redundancy. ¶1.29- 1.31 are new additions which replace and expand on the parenthetical comment in ¶8 of IT-270R3, which read: (subject to subsections 126(4.1) and (4.2), which concern the no economic profit and short-term security acquisitions rules, respectively) ¶1.32- 1.35 (formerly included in ¶11 of IT-270R3) has been revised to omit the last sentence of former ¶11 and to add a discussion on what is meant by paid by the taxpayer for the year. ¶1.39 replaces and expands on the partnership information contained within parenthesis at ¶1- 2 of IT-270R3. ¶1.41 (formerly included in ¶15 of IT-270R3) has been revised to de-emphasize the word spouse and place greater emphasis on the filing of a valid, foreign, communal return. ¶1.42 (formerly included in ¶16 of IT-270R3) has been expanded to reflect amendments to section 261 and the CRA’s position regarding consistency in exchange rate methodologies. ¶1.46 (formerly included in ¶20 of IT-270R3) has been revised to clarify the situation of income arising from property which pertains to or is incidental to a foreign business. ¶1.49 (formerly included in ¶21 of IT-270R3) now references the Canada-UK Income Tax Convention. ¶1.51 (formerly included in ¶22 of IT-270R3) now contains a sentence to address subsection 91(5). ¶1.52 is a new paragraph added to point out that where a treaty is applicable; the treaty may have its own income sourcing rules which supersede those of the Act, but only for the purposes of eliminating double taxation in accordance with the treaty. ¶1.53 (formerly included in ¶23 of IT-270R3) now includes the phrase or profit generating activities for greater clarity, as well as a bullet referencing transportation or shipping businesses. ¶1.54 is a new paragraph added to reflect the jurisprudence on additional factors and the weighting of various factors when determining the location of the source of the business income. ¶1.57 (formerly included in ¶25 of IT-270R3) has been revised to change place to physical place to remove ambiguity. ¶1.58 (formerly included in ¶26 of IT-270R3) contains new sentences that reflect additional factors concerning the situs of income and their weight, as judicially addressed. ¶1.62 (formerly included in ¶3 of IT-395R2) has been revised to add and title was transferred to the second sentence and to add the third sentence for greater clarity. ¶1.63 (formerly included in ¶3 of IT-395R2) has been revised to add the phrase under the Act to remove ambiguity and to differentiate between foreign deemed dispositions and deemed dispositions under domestic law. ¶1.65 (formerly included in ¶4 of IT-395R2) now includes examples and a discussion of the relative weighting of various factors for consideration. ¶1.69 is a new paragraph added to address TFSAs and RRSPs. ¶1.70- 1.72 (formerly included in ¶37 of IT-270R3) has been revised to reflect legislative changes effective for the 2005 and later tax years, to make reference to the additional definitions involved, and to reference Guide 5000-G, General Income Tax and Benefit Guide. ¶1.73 (formerly included in ¶40 of IT-270R3) has been revised to change the treaty in the example to the Canada-India Treaty. ¶1.76 (formerly included in ¶2 of IT-270R3) has been revised to match the marginal note of subsection 120(1). ¶1.79 (formerly included in ¶3 of IT-270R3) has been expanded to better explain the operation of section 114 and subparagraphs 126(1)(b)(ii) and 126(2.1)(a)(ii). ¶1.80 (formerly included in ¶30 of IT-270R3) now includes the phrase not under the laws of the foreign jurisdiction in the first paragraph for greater clarity. ...

As was the case last year when negotiating with the Public Service Alliance of Canada, these negotiations required that the CRA and the Board carefully balance the interests of the CRA while keeping in mind government-wide considerations, including the elimination of severance. ... Commissioner 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. ...

It is important to always provide all relevant information to CRA to allow for a complete consideration of the issue, at the assessing, audit, and objection stages. ... While an application for taxpayer relief from interest or penalties is under consideration, collection action will continue on any undisputed amount and the amount is due and payable. ...

Other promoters stated their requests were very complex and required additional tasks, including: driving applicants to medical appointments, pre-screening DTC applications to ensure that only valid DTC requests are submitted to the CRA, following up with medical practitioners to ensure that the right information is given on the DTC certificate, operating their own call centres to support their clients, advertisement and office overhead, geographic considerations for overhead expenses, postage for shipping documents across Canada to obtain doctor reports and signatures on the DTC certificate, and adjusting multiple tax returns for anyone who could have supported the person with a disability. ... The CRA will continue its efforts to constantly improve the service it offers to Canadians by addressing the items that can be acted on in the short term and give due consideration to other items as part of our long term strategy. ...

Consideration should be given to introducing higher-level sign-off requirements in cases involving substantial amounts of evaded taxes, complex arrangements, or new issues of law. ... Consideration should be given to introducing procedures to ensure that large or complex cases are reviewed by specialists before acceptance into the VDP. ...

Otherwise, the additional consideration (i.e., the amount that is over and above the FMV) that was paid to the corporation may be considered to be assistance for the purposes of calculating the CPTC or the PSTC, or an acquisition of interest in the corporation or the corporation’s business or property, depending on the facts and circumstances of the situation. ... In the case of film and video productions, crowdfunding allows producers to finance, in whole or in part, their projects or promotional activities usually in return for non-monetary considerations offered to contributors (i.e., the donation model). ...

If an item plays a minor or subordinate role, or if no part of the consideration can reasonably be attributed to it, it is likely an amenity. ... Consideration Sch. V, Part 1, para 6(b) 17. The consideration for a supply of accommodation should exceed $20 for each day of occupancy. If the consideration does not exceed $20 for each day of occupancy, the supply is exempt and is not considered short-term accommodation because it would be included in the non-taxable portion of a tour package. ...

It is within this context that the S ustainable Development Strategy 2004-2007 will unfold, and as such, takes into consideration internal and external realities. ... To assess how well sustainable development considerations are being integrated into programs, we will develop an audit program and measure progress over time. ... In terms of facilitating the measurement of sustainable development in programs, policies, and plans, our main indicator will be the presence of sustainable development considerations in key CRA planning tools, and the ultimate measure will be the tabling of triple bottom line (economic, social, and environmental) annual reports. ...

"Printed matter that is to be made available to the general public, without charge, for the promotion of tourism, where the printed matter is (a) imported by or on the order of a foreign government or an agency or representative of a foreign government; or (b) imported by a board of trade, chamber of commerce, municipal or automobile association or similar organization to which it was supplied for no consideration, other than shipping and handling charges. ... "Goods that are imported by a particular person where the goods are supplied to the particular person by a non-resident person for no consideration, other than shipping and handling charges, as replacement parts under a warranty in respect of tangible personal property. ... Therefore, if a three-year subscription was purchased and paid for prior to 1991, even if the subscription is for a period after 1990, no GST applies to the consideration. 67. ...

Subsection 223(1) of the Act imposes a statutory obligation on all registrants making a taxable supply to indicate to the recipient of the supply, either: (a) the consideration paid or payable by the recipient for the supply and the tax payable in respect of the supply in a manner that clearly indicates the amount of the tax; or (b) that the amount paid or payable by the recipient for the supply includes the tax payable in respect of the supply. 3. ... It provides that no ITC may be claimed by a registrant in respect of a particular taxable supply except to the extent that both the nature of the supply and the consideration for the supply are reasonable with respect to the commercial activities of the registrant. 16. ... These books and records must capture the following: (a) sufficient information to identify the location where the taxable supply was made; (b) sufficient information to identify the reporting period when the GST in respect of the supply was paid or became payable; (c) the consideration paid for the supply; (d) the amount of GST paid or payable; and (e) sufficient information to identify the nature and quantity of the supply. 40. ...