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In making a determination of whether or not a PE exists, there are numerous factors to be taken into consideration in deciding if the basic elements for a PE exist. ... Other considerations Other types of PEs This memorandum focused on the general definition of a PE. ... Consideration should be given to whether one of these types of PEs could be applicable to the situation under review. ...

Other considerations 5. A charity that is seeking to backdate its effective date of registration to a previous fiscal period must complete and file with the Charities Directorate, any and all information returns (Form T3010) that have become due under these circumstances before registration can be granted, otherwise the registration date cannot be backdated. 6. ... Footnote 4 This consideration is noted to highlight a possible advantage of choosing the first day of a fiscal period as the effective date of registration. ...

The resident consumer is not required to pay any consideration to anyone for the good. ... This is because the non-resident is supplying the catalogues to the residents for no consideration. ... The consideration for the supply of the inspection services is $1,000. ...

For treaty and inter-provincial co-productions, will the CRA give consideration to the fact a co-producer may command higher fees because of his/her stronger and more active role in producing a film? ...

Excise and GST/HST News- No. 95 Table of Contents Form RC4616 – Simplified filing procedures concerning existing elections for nil consideration No offset of GST/HST and QST amounts for selected listed financial institutions with a consolidated filing election Service standard for responding to written requests for GST/HST rulings and interpretations Online services for GST/HST accounts Representatives – request or delete authorizations online Prescribed rates of interest What’s new in publications Enquiries Form RC4616 – Simplified filing procedures concerning existing elections for nil consideration As discussed in the Excise and GST/HST News – N o 91 and N o 94, section 156 of the Excise Tax Act permits corporations resident in Canada and Canadian partnerships that are: registrants engaged exclusively in commercial activities; and specified members of the same qualifying group to jointly elect to treat taxable supplies (with certain exceptions) made between them as having been made for no consideration. ... These parties must complete and file Form RC4616, Election or Revocation of an Election for Closely Related Corporations and/or Canadian Partnerships to Treat Certain Taxable Supplies as Having Been Made for Nil Consideration for GST/HST Purposes. ...

Other considerations Indicate with your request if this is the first or second review request. ...

Housing and charitable registration Guidance Reference number CG-022 Issued February 7, 2014 Table of contents Summary Housing that relieves poverty Housing that includes specially adapted facilities, services, or other amenities Other considerations Applying for registration as a charity under the Income Tax Act Footnotes This guidance updates and replaces Policy Statement CPS-020, Applicants that are Established to Relieve Poverty by Providing Rental Housing for Low-Income Tenants. ... Other considerations 13. When an organization rents housing to individuals who are not eligible beneficiaries of charitable relief, this activity must either: qualify as investment property income generating a fair market value return meet the related business provisions of the Income Tax Act. ...

Special considerations 7.1 Political purposes and political activities 7.1.1 Political purposes are not charitable 7.1.2 Political activities 7.2 Canada's charities and anti-terrorism measures: What you need to know Appendix A: Questions and answers Footnotes 1. ... Special considerations 7.1 Political purposes and political activities The Charities Directorate's Policy statement CPS-022, Political activities provides registered charities with information on political activities and allowable limits under the Income Tax Act. ... The most important consideration will be the legal context in which the government's policy exists. ...

Election for nil consideration Under proposed subsection 157(2.1) a participating employer of a pension plan and a master pension entity of the pension plan would be permitted to jointly elect to have every actual taxable supply made by the participating employer to the master pension entity be deemed to have been made for no consideration. ... Therefore, the employer would be eligible to make the election to deem actual supplies made to the master pension entity as being made for no consideration. ... Therefore, neither employer would be eligible to make the election to deem actual supplies made to the master pension entity as being made for no consideration. ...

The following are factors for consideration when determining materiality: Claim size – An amount that is considered material for one claimant may not be considered material for another. ... An important consideration relevant to determining the scope of the review involves coordinating the review with the RTA such that the FR includes procedures that assist the RTA on joint issues included in the RTA's review plan. ... Such considerations are the responsibility of the local management. Previous chapter Table of contents Next chapter Date modified: 2015-06-24 ...