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Whether a review with or without a site visit is chosen is a decision based on numerous considerations. ... The FR’s demonstrated openness and consideration of all of the facts prior to making a disallowance should persuade the claimant that all expenditures that were disallowed were given every consideration prior to the decision being made. ... If both conditions are met, the appeals officer will refer the claim to the SR&ED Division for financial review consideration. ...

If you are currently, or are thinking of requesting to work virtually, learn more about security considerations and your obligations Any time you are working away from CRA premises (on a laptop or other device), you must protect CRA information and equipment. ... One such constraint is consideration for the public’s perception of both our on and off-duty actions. ... When we comply with official languages and employment equity requirements, and treat one another with consideration and inclusiveness, we value our diversity. ...

A response was issued to the petitioner within the time limit specified by the Auditor General Act (1995). 4.5 Future Considerations The SD program at the CRA will continue to evolve to respond to both changing requirements of the CRA and the Government of Canada, including the new Federal Sustainable Development Act, whichis intended to make environmental decisions more transparent and accountable to Parliament. ...

Ethical considerations VII.B. Dissemination and accessibility requirements VII.B.i. ... Ethical considerations 28. The CRA expects any charity conducting or funding charitable research that involves human subjects to assess, at the outset, whether any ethical questions might arise. ... Research is a charitable activity when any decisions regarding the protection and use of intellectual property arising from research results are made with the charitable purpose and its associated public benefit as the primary consideration. ...

10-Year Repayment Rule Proportional Repayment Rule Tax payable Tax payable on DAPs Tax deduction at source Tax payable on non-qualified investment Tax payable where inadequate consideration Tax payable on an advantage Tax payable on use of property as security Waiver of liability Online services My Account MyCRA – the web app for individual taxpayers on the go Electronic payments For more information What if you need help? ... Tax payable where inadequate consideration This tax applies for a calendar year if, in the year, an RDSP trust: disposes of property for an amount less than the FMV of the property at the time of the disposition, or for no amount at all; or acquires property for an amount greater than the FMV of the property at the time of acquisition. ... Amount of tax payable The amount of tax payable for each disposition or acquisition is: the amount by which the FMV differs from the consideration; or if there is no consideration, the amount of the FMV. ...

10-Year Repayment Rule Proportional Repayment Rule Tax payable Tax payable on DAPs Tax deduction at source Tax payable on non-qualified investment Tax payable where inadequate consideration Tax payable on an advantage Tax payable on use of property as security Waiver of liability Online services My Account MyCRA – Mobile app MyBenefits CRA – get your information on the go Electronic payments For more information What if you need help? ... Tax payable where inadequate consideration This tax applies for a calendar year if, in the year, an RDSP trust: disposes of property for an amount less than the FMV of the property at the time of the disposition, or for no amount at all; or acquires property for an amount greater than the FMV of the property at the time of acquisition. ... Amount of tax payable The amount of tax payable for each disposition or acquisition is: the amount by which the FMV differs from the consideration; or if there is no consideration, the amount of the FMV. ...

This calculation takes into consideration the terms "qualified expenditure" and "SR&ED qualified expenditure pool" which are defined in the Act. ... Legislative References Income Tax Act Subsection 127(9) Definition of "contract payment" Subsection 127(9) Definition of "qualified expenditure" Subsection 127(9) Definition of "SR&ED qualified expenditure pool" Subsection 127(13) Agreement to transfer qualified expenditures Subsection 127(14) Identification of amounts transferred Section 251 Arm's length 7.5 Other considerations when transferring qualified SR&ED expenditures between persons not dealing at arm's length 7.5.1 Different year-ends for the performer and the payer Since ITC eligibility arises at the performer's tax year-end, the transfer is made in respect of a particular tax year of the performer (transferor). ... Legislative References Income Tax Act Subsection 69(1) Inadequate considerations Subsection 127(11.8) Interpretation for non-arm's length costs 12.4 Leasing of a property is deemed to be the rendering of a service for lease costs incurred prior to 2014 The following rule and example contained in section 12.4.1 are applicable to lease costs incurred before 2014. ...

Claim Review Manual for Research and Technology Advisors SR&ED Program Previous Chapter CRM Table of Contents Next Chapter Chapter 6.0 Documenting the review Table of contents 6.1.0 Summary of chapter 6.2.0 Requirements of chapter 6.3.0 Users of the RTA's documents 6.4.0 Definitions / explanation of terms 6.5.0 Basic principles 6.6.0 Types of working papers and supporting documentation 6.6.1 Documents received from the tax centre 6.6.2 Documents received from the Control Function 6.6.3 Review plan 6.6.4 Records of communications 6.6.5 Correspondence 6.6.6 Documentation related to outside consultants 6.6.7 Results of RTA's work 6.6.8 Other Supporting Evidence 6.7.0 Documents supporting the RTA's decisions 6.7.1 General requirements 6.7.2 Detail required to support the RTA's work 6.7.2.1 No technical issues but the FR requires some assistance 6.7.2.2 All issues resolved in claimant's favour, no on-site visit made 6.7.2.3 All issues resolved in claimant’s favour, following an on-site visit 6.7.2.4 Not all issues resolved in claimant's favour 6.8.0 The SR&ED Review Report 6.8.1 Identification 6.8.2 Summary of results by tax year 6.8.3 Review issues 6.8.4 Review methodology 6.8.5 Information and supporting evidence reviewed 6.8.6 Review observations, determinations, conclusions, and other decisions 6.8.6.1 Documenting eligibility determinations 6.8.6.2 Documenting Unsubstantiated claims 6.8.6.3 Formal statements to be used in section 6 of the SR&ED review report 6.8.6.4 What to avoid in documenting determinations 6.8.7 Working with the claimants 6.8.8 Claimant concurrence 6.8.9 Recommendations for future claims 6.8.10 Other financial review considerations 6.8.11 Signatures 6.9.0 Other methods to document the RTA's work 6.9.1 Memos 6.9.2 Short SR&ED review report 6.9.3 SR&ED review report for a partnership 6.9.4 SR&ED review report addendum 6.10.0 Formatting and indexing the TF98 file 6.1.0 Summary of chapter Documenting the review carried out by the research and technology advisor (RTA) is discussed in this Chapter. ... Nevertheless, this section provides an additional opportunity for the RTA to do so. 6.8.10 Other financial review considerations The purpose of this section is to document any concerns about the claim believed to require the attention of the FR but which are not elsewhere indicated in the SR&ED review report. ... Other financial review considerations" – if the names of the individual partners, their Business numbers/ SINs, and their percentage of ownership is known, this information can be placed in the body of this section. ...

Table of contents 1.0 Purpose 2.0 Overview 3.0 Meaning of terms 3.1 Amount received 3.2 Entitled to receive 3.3 Reasonably be expected to receive 4.0 Government and non-government assistance 4.1 Definitions 4.1.1 Government assistance 4.1.2 Non-government assistance 4.2 General considerations 4.2.1 Factors used to determine whether an amount is assistance 4.2.2 The context of the assistance agreement 4.2.3 Example – Forgivable loan 4.3 Application of the rules 4.3.1 The pool of deductible SR&ED expenditures 4.3.2 Qualified SR&ED expenditures 4.3.3 Example – Reduction of qualified SR&ED expenditures 4.4 Assistance received or receivable by a non-arm's length party 4.4.1 Allocation of assistance 4.4.2 Example – Allocation of assistance 4.5 Provincial and territorial research and development tax credits 4.5.1 Treatment of assistance related to the prescribed proxy amount and impact on the pool of deductible SR&ED expenditures 4.5.2 Treatment of assistance related to the prescribed proxy amount with respect to qualified SR&ED expenditures 4.5.3 Quebec's R&D tax credits 4.5.4 Ontario's R&D tax credits 4.5.5 Super-allowance benefit amount 4.6 Repayment of assistance 5.0 Contract payments 5.1 Overview 5.2 Definition of a contract payment 5.3 Differences between assistance and contract payments 5.4 Who is entitled to an investment tax credit? ... Although consideration should also be given to the nature of the functions performed by an entity, a public authority is generally an entity that: has a duty to the public; is subject to a significant degree of government control; and uses its profits for the benefit of the public. ... Legislative References Income Tax Act Paragraph 12(1)(x) Inducement, reimbursement, etc Subsection 127(9) Definition of “non-government assistance” 4.2 General considerations 4.2.1 Factors used to determine whether an amount is assistance Determining whether an amount received by a claimant is assistance will depend on the particular facts of the case. ...

Although automobile taxable benefits, including standby charges, may not involve an expenditure incurred in the year, in practice an amount in respect of such benefits can be included as salary or wages if the amount represents a reasonable estimate of the actual costs incurred and does not include any GST / HST or PST (unless no input tax credit refund was claimed) and the automobile expenses and CCA to which the standby charge relates are not included in calculating business income. 3.2 GST / HST or PST considerations Some taxable benefits (for example, non-cash benefits) included on the employee's T4 slip may include a GST / HST or PST component. ... Generally, the corporation is to reduce the related expenditure by the amount, if any, by which (i) the fair market value of the share exceeds (ii) that portion of the amount of the consideration that the issuing corporation has received for issuing the share that is added to, and not deducted because of a provision of the Income Tax Act from, the paid-up capital of the class of shares that includes the share. ... The nature and sources of available information will be a key consideration in developing an appropriate labour allocation method. ...