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Phase 2 of the audit has been included in the Audit, Evaluation, and Risk Branch’s (AERB) Risk-Based Audit and Evaluation Plan as part of the 2017-2019 Inventory of Engagements for Consideration. ... Procedures for Taxpayer Relief and/or other similar considerations are established and consistent with national guidelines, documented, and authorized. ...

In practical terms, it means that the first $100,000 of deduction the claimant took from their pool of deductible SR&ED expenditures was made of the overstated expenditures without any consideration for any other expenditures in the pool of deductible SR&ED expenditures. Similarly, the first $15,000 of ITC they deducted from Part I tax payable came from was made of the overstated ITC, without any consideration for the $7,000 of ITC available at the beginning of their tax year. ...

Taking all of these factors into consideration, we start from the assumption that the vast majority of charities want to comply and that achieving good compliance starts with education. ... Having access to stakeholders that can provide us with "on the ground" type considerations of the challenges they face, has had a direct impact on how the charities program has evolved over the years. ...

.), which was later confirmed by the Federal Court of Appeal, gave the following explanation of when non-related persons are considered not to be dealing with each other at arm's length: “Parties are not dealing at arm's length when the predominant consideration or the overall interest or the method used amount to a process that is not typical of what might be expected of parties that are dealing with each other at arm's length.” ... Employees who are shareholders, corporate directors, corporate officers, or members of a corporation without share capital Determining if an employee, who exercises another corporate responsibility for the corporation, is dealing at arm's length with the employer involves the same considerations as with any other employment relationship. ...

As outlined in the above-noted information circular, the CASD will accept a request under the Mutual Agreement Procedure (MAP) that involves a request for a downward transfer pricing adjustment only in the following circumstances: A corresponding upward adjustment has been accepted for consideration by the foreign tax authority; The foreign competent authority takes steps to resolve the case under the MAP by reviewing the case, providing the Canadian competent authority with a detailed analysis as to why the foreign authority agrees with the adjustment and agrees to negotiate the case; The request for competent authority assistance is made within the time limits of the applicable treaty; and The issue is not one that the Canadian competent authority has decided, as a matter of policy, not to consider. 13. ... The taxpayer should be informed that the downward transfer pricing adjustment must be referred to the Assistant Director of Audit or the Director of the ITD for consideration of its appropriateness. ...

After submitting a Request, you must inform Competent Authority of any material change in the information or documentation previously submitted as part of, or in connection with, the Request, as well as new information or documentation relevant to the issues under consideration. If you do not provide complete and accurate information or make a misrepresentation then the Competent Authority may suspend or terminate its consideration of your Request. 13. ...

. ¶1.9 (formerly ¶4(d) of IT-128R) has been updated to include a consideration of the amount of the expenditure in relation to a taxpayer’s expenses and annual profits when determining whether an expenditure is made on capital or income account. ... Section 68 was amended to apply in circumstances where consideration received or receivable from a person is in part for a restrictive covenant (as defined by subsection 56.4(1)) granted by a taxpayer. ...

In general, under subsection 249(1), the threshold amount of a person for a fiscal year is calculated based on the total consideration for taxable supplies made in Canada by the person, including those of associates, in the immediately preceding fiscal year. When calculating this amount, a person does not include consideration attributable to supplies of financial services, supplies by way of sale of capital real property, supplies of zero-rated exports of goods and services, and goodwill. 5. ...

Accordingly, in order to be eligible to claim an ITC in respect of a particular supply, an employer must generally be able to demonstrate that it acquired the particular supply, that it did so for consumption, use or supply in the course of its commercial activities, and that it was the recipient that was liable to pay the consideration (and related GST/HST) for the supply. ... It is a question of fact whether, under the Policy (or another agreement), the insurer supplies additional services to the employer other than those considered to form part of the supply of insurance, and whether the employer is liable to pay separate consideration for such services. ...

Taking into account the need for effective and timely service delivery and privacy considerations to enable the protection of our most sensitive assets. ... Initiative-based working groups that assess the initiative/topic of interest, recommend a go-forward approach for the Agency for consideration by senior management, and work with the appropriate stakeholders to implement the recommendation(s), as required. ...