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Required Withholding From Amounts Paid to Non Residents Providing Services in Canada
While it may not always be necessary for the non-resident to apply for a waiver of withholding in such cases (see ¶s 56-63), the payer must retain the appropriate information and documentation supporting an allocation for potential CRA consideration. ... Also, if the non-resident received a waiver in a previous year but did not file a return for that year, and the filing due date specified under section 150 of the Act has passed, the TSO will take all of this into consideration before issuing any further waiver of withholding. ¶ 54. ... Also, if the non-resident received a waiver in a previous year but did not file a tax return for that year, and the filing due date specified under section 150 of the Act has passed, the TSO will take all of this into consideration before issuing any further waiver of withholding. ¶ 84. ...
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Information for Students – Educational Institutions outside Canada
Some common areas for consideration are listed below: Income Any foreign income you report has to be shown in Canadian dollars on your Canadian income tax return (this also applies to deductions claimed). ... Tuition, education, and textbook amounts In choosing a foreign educational institution, an important consideration is whether you will be able to claim the tuition fees you paid and the related education and textbook amounts. ...
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Deferred Profit Sharing Plans
The following special rules apply to a revoked plan: the revoked plan is deemed not to be a DPSP, an employee profit sharing plan, or a retirement compensation arrangement; the revoked plan cannot be accepted for registration or be deemed to have become registered under subsection 147(5) of the Act until at least one year after the effective date of revocation; the trust is taxable on its taxable income for a taxation year if the trust was governed by a revoked plan for any part of that year; the employer cannot deduct from its income payments made to a trustee under the plan at a time when the plan is a revoked plan; any amount received by a beneficiary under the plan will be included in the beneficiary's income to the extent it would have been included in income under subsection 147(10) of the Act if the plan had been a deferred profit sharing plan; the value of any funds or property appropriated to or for the benefit of a taxpayer who is an employer making payments to the plan, or a corporation with which such an employer does not deal at arm's length, to the extent it would have been included in income under subsection 147(13) of the Act if the plan had been a deferred profit sharing plan (see 42 below); and if property of a revoked plan is disposed of to, or is acquired from, a taxpayer for a consideration other than the fair market value of the property at the time of the transaction, the difference between the consideration and the fair market value will be taxable, as provided in 45 below. ...
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Claims for Partnerships Policy
This additional allocation is based on what is reasonable in the circumstances, taking into consideration the investment in the partnership, including the debt obligations of the partnership, of each such member of the partnership. ... The allocation is based on what is reasonable in the circumstances, taking into consideration each non-specified member's investment in the partnership, including debts of the partnership. ...
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Retirement Compensation Arrangements Guide – 2016
Box 20 – Other amounts Complete box 20 if the RCA trust: disposed of property for consideration less than the fair market value (FMV) of the property; acquired property for consideration greater than the FMV of the property; permitted the RCA trust's property to be used for consideration less than the FMV of such use. Under subsection 56(11), the amount to include in box 20 is the difference between the consideration and the FMV. ...
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T4033 - Completing the Registered Charity Information Return
However, the foundation will not be considered to have acquired control if it has not bought or otherwise acquired for consideration more than 5% of any class (voting or otherwise) of shares of the corporation. A foundation that receives a gift of shares in the year that results in the foundation having control of a corporation will only be considered to have acquired control if, in the current or any previous year, it bought or otherwise acquired shares for consideration that total more than 5% of the issued shares of any class of the capital stock of the corporation. If the same foundation were to buy or otherwise acquire shares of the same corporation for consideration that, when added to any shares previously bought or otherwise acquired for consideration, are more than 5% of the issued shares of any class of the capital stock of the corporation, the foundation will be considered to have acquired control of the corporation. ...
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Goods and Services Tax and Harmonized Sales Tax (GST/HST) Administration
Any consideration of testing will, therefore, include consideration of the costs of testing and benefits to be obtained. ... Documented procedures are in place for processing the return of goods including consideration of GST/HST impacts. ... Mixed supplies A supply of products (taxable, exempt and/or zero-rated) combined together and supplied for one consideration. ...
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Chapter History: S1-F2-C2, Tuition Tax Credit
. ¶ 2.13 (formerly included in ¶6 of IT-516R2) has been updated to reflect the new address to which enquiries should be sent for consideration as a university outside Canada. ¶2.15 (formerly included in ¶7 of IT-516R2) has been revised to clarify the meaning of commute for purposes of paragraph 118.5(1) (c). ¶2.16 has been added to provide references to other CRA publications relevant to students attending universities outside Canada. ¶2.19 has been added to explain the CRA’s position regarding online attendance for purposes of the requirement for full-time attendance in paragraph 118.5(1) (b). ¶2.20 has been added to explain the CRA’s position regarding correspondence courses for purposes of the requirement for full-time attendance in paragraph 118.5(1) (b). ¶2.22 (formerly included in ¶13 of IT-516R2) has been revised to include the meaning of enrolled for purposes of paragraph 118.5(1) (a) and (c). ¶2.23- 2.25 (formerly included in ¶16 and 17 of IT-516R2) have been amended to clarify whether a student in receipt of a scholarship, fellowship, bursary or prize may claim a tuition tax credit in respect of the student’s tuition. ¶2.26 has been added to address whether a student may claim the tuition tax credit where the student’s tuition fees are paid by the employer of the student’s family member. ¶2.28 has been added to provide an example of when a tuition tax credit would not be available pursuant to subparagraph 118.5(1) (a) (iii.1) or (v). ¶2.29 (formerly included in ¶14 of IT-516R2) now makes reference to the student’s ability to carry forward unused tuition amounts to be used in future years, pursuant to subsection 118.61(1), added by 1998, c. 19, s. 28(1), applicable to the 1997 and subsequent tax years. ¶2.31 (formerly included in ¶24 of IT-516R2) has been updated to reflect the amendment to subparagraph 118.5(1) (b) (i), amended by 2011, c. 24, s. 29(2), applicable to tuition fees paid for the 2011 and subsequent tax years. ¶2.36 and 2.37 have been added further to the introduction of subsection 118.5(3), concerning ancillary fees and charges. ...
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GST/HST News No. 43 (Winter 2001 - 2002)
In the case of a rebate to a non-resident who is not in the business of resupplying accommodation, the rebate can only be credited in the following two circumstances: the payment for the supply of the eligible accommodation is made at a place outside Canada where the supplier or its agent is conducting business; or where the eligible accommodation is supplied as part of a tour package that includes other goods or services (other than meals or room-related charges): the recipient pays to the supplier a deposit of at least 20% of the total consideration for the tour package at least 14 days before the first day any eligible accommodation in the package is made available under the agreement, and the payment is made by means of a credit card or charge card issued by, or a cheque, draft or other bill of exchange drawn on an account outside Canada with, a non-resident institution that is a bank, cooperative credit society, trust company or similar institution. ...
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Sample pro forma - Declaration of Trust
In addition to any other disability assistance payments Footnote 1 that are required to be paid to the beneficiary in the year, if the beneficiary is transferring an amount from another registered disability savings plan and the beneficiary attained the age of 59 years before the calendar year in which the transfer occurs, the Plan will make one or more disability assistance payments to the beneficiary whose total will be equal to the amount by which: the total amount of disability assistance payments that would have been made from the prior plan in the year if the transfer had not occurred exceeds; the total amount of disability assistance payments made from the prior plan in the year. 9 Termination of the plan After taking into consideration the assistance holdback amount and designated provincial program repayments, any remaining amount in the Plan will be paid to the beneficiary or to his or her estate. ...