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The rates vary depending on the risk and the taxpayer population under consideration. ...

For these two audiences, there were two key points of consideration relating to customer service where they feel the CRA can improve upon. ...

Where this is the case, only the fruit juice content is taken into consideration when determining whether the 25% by volume threshold has been met. ... Although we consider placement of a product in store aisles as a relevant consideration, it alone is not considered a determinative factor. ... The consideration paid by the customer is based on a per person or per serving charge. ...

Any amount paid or credited to a non-resident in consideration for the non-resident's agreeing to guarantee, in whole or in part, the principal amount of an obligation of a resident of Canada is deemed to be a payment of interest on that obligation. When a non-resident has entered into an agreement to lend money or make money available to a resident of Canada, any amount paid or credited to the non-resident in consideration for such agreement is deemed to be a payment of interest provided that, on the date such agreement was entered into, Part XIII tax would have applied to interest payable on any obligation issued pursuant to that agreement- 214(15). ... The dividend that is deemed to be paid to the non-resident is equal to the amount by which the fair market value of consideration (other than shares of the purchaser corporation) received exceeds the paid-up capital of the shares transferred. ...

., a province where the HST applies: Nova Scotia, New Brunswick and Newfoundland-see paragraph 22): (A- B) × C where A = the total of: (i) tax payable on the claimant's last acquisition or importation of the property; (ii) tax payable in respect of improvements to the property acquired, imported or brought into a participating province after the property was last acquired or imported; (iii) tax that would have been payable in either of the preceding situations but for subsection 153(4) Footnote 3 or section 167 Footnote 4 applying or the fact that the property or improvements were acquired by the claimant for consumption, use or supply exclusively in commercial activities; and (iv) tax under section 218 and section 218.1 (tax payable on imported taxable supplies), and Division IV.1 (tax self-assessed on property brought into a participating province from a non-participating province) that the person would have been liable to pay if the property or improvement were not for consumption, use or supply exclusively in the course of commercial activities of the person; B = the total of (i) any tax included in A (above) that the person was exempt from paying under any other Act or law; (ii) all amounts of tax referred to in A (i) and A (ii) above which the claimant was entitled to recover by way of a rebate, refund, or remission or would have been entitled to recover, if the property or improvement had been acquired for use exclusively in activities that are not commercial activities, other than ITCs and amounts referred to in B (i); (iii) the amounts of tax referred to in A (iii) and A (iv) above which the claimant was entitled to recover by way of a rebate, refund, remission or otherwise under this or any other Act or law or would have been entitled to recover if the tax had been payable and the property or improvement had been acquired for use exclusively in activities that were not commercial activities, other than ITCs and amounts referred to in B (i); and C = the lesser of 1, and fair market value at the time the basic tax content is being determined divided by the; consideration payable on the last acquisition + consideration for improvements Example Property Co. ... Return to footnote 2 referrer Footnote 3 The provisions of subsection 153(4) apply where a supplier accepts property that is used tangible personal property (or a leasehold interest therein) as full or partial consideration for other tangible personal property. ...

The delegated manager will take a number of factors into consideration and make a determination on the matter. ... Appendix B- How to manage a conflict of interest In determining the appropriate measure, or combination of measures, to manage a particular conflict of interest, your delegated manager may take the following factors into consideration: the nature and scope of your specific duties; the CRA’s institutional risks related to the specific conflict of interest; the value and types of assets and liabilities disclosed; the nature of the private interests and/or outside activities/employment; how the situation would appear to a reasonable member of the public; the possibility that you will be placed in a situation where you will have to choose between your loyalty to the CRA and your loyalty to your private interests and/or outside activities; how similar situations have been managed in the past and what compliance measures have been imposed; and the actual costs that may be incurred to implement the measure(s), as opposed to the potential that the private interests and/or outside activities represent for a conflict of interest. ... The decision to reduce or waive the limitation period will consider: the circumstances under which the termination of their service occurred; the general employment prospects of the employee or former employee; the significance to the CRA of information acquired by the employee or former employee by virtue of their role at the CRA; the desirability of a rapid transfer of the employee’s or former employee’s knowledge and skill from the CRA to private or other governmental sectors; the degree to which the new employer might gain unfair commercial or private advantage by hiring the employee or former employee; the authority and influence the employee had in their position at the CRA; and, any other consideration at the discretion of the Agency. ...

FAB has developed action plans to address the audit findings, with consideration given to balancing risk and cost. ... Preparation of the SIP involves consideration of all possible funding strategies, including base funding, funding from the strategic investment reserve, and funding from the Treasury Board. ... In this process, the ITB is responsible for identifying the projects that fall in their areas of responsibility for consideration by FAB and the AMC. ...

The litigation process requires that the Tax Appeals program assist the Department of Justice (DoJ) in the preparation of the Tax Court cases including pleadings, discoveries, attendance at trials and consideration of proposals for settlement. ... Beyond the analysis of program results, consideration should also be given to measurement of expected results of new initiatives. ... Some examples of invalid appeals include those that were filed with the court: where no objection was previously filed, where the appellant has waived the right to appeal, with no tax in dispute (ETA), with an objection that is still under consideration by the Minister. ...

This section describes the: SR&ED Review Report; Presentation of technical and financial review findings; Dispute resolution process; and Appeals process. 3a) SR&ED Review Report After a site visit, and taking into consideration any more representations from the claimant, the results of the RTA's work will be documented in an SR&ED Review Report, which will be given to the claimant. ... The claimant may do one or all of the following. ask for an explanation or clarification of the rationale for the RTA's and the FR's determinations on the issues; rebut the CRA's position, in writing; or give new information for consideration. ... If a claimant has a concern regarding an outside consultant under consideration, this concern should be communicated to the RTA who, along with management, will try to resolve the concerns raised by the claimant. ...

This document: Gives an overview of the types of entities to whom a third-party payment can be made; Explains the criteria to be met so a payment to each type of entity may be considered eligible; Highlights the considerations to be made when making payments to research chairs; Highlights the differences between third-party payments and contract expenditures for SR&ED performed on behalf of the claimant; Outlines the process and criteria for certain entities to become "approved"; and Informs agricultural organizations and agricultural producers about available SR&ED investment tax credits. 1.2 Policy The term third-party payments is not specifically defined in the Act. ... No consideration will be given to lost production value of a piece of land or equipment used for the prosecution of SR&ED. For a proprietorship, no consideration will be given to the time the proprietor producer expends on an SR&ED project. ...