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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. ...

These assets would then be tested for an eligible purpose. 1.63.2 In situations such as those in ¶1.63.1 but where the debt represents only partial consideration for the share acquisition, if some assets do not meet the purpose test, the taxpayer may adopt a flexible approach in linking the debt to the eligible assets formerly held by the acquired corporation, similar to the situation described in ¶1.38. ... In order for the purchaser of the preferred shares to meet the purpose of earning income requirement in paragraph 20(1)(c), consideration must be given to the income producing capacity of the issuer of the preferred shares. ... Discounts arising on the issuance of debt obligations 1.94 Where money is borrowed with a stated rate of interest and in consideration of a promise to pay a larger amount, subsection 20(2) will deem the larger amount to be the amount borrowed for purposes of paragraph 20(1)(c). ...

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. ...

., 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 footnote2 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. ...

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. ...

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. ...

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. ...

Also, it does not take into consideration certain complexities particular to the National Capital Region, such as it serving 13 different branches and related management teams. ... This forum will enable pan-Agency discussions to take place taking into consideration financial and human impacts. Responsibilities: Provide guidance and recommendations to help set strategic direction of the Real Property Program Be a sounding board for proposed changes to the real property corporate policy instruments that may have broader CRA implications (financial and human considerations) Provide a forum for information sharing on emerging strategic real property matters from PSPC/central agencies Oversight of the CRA’s real property portfolio Real Property Management Committee To provide advice and develop recommendations to the Real Property and Service Integration Directorate’s Directorate Management Committee on strategic direction and current/emerging issues and their implications on the delivery of the Real Property Program. ...

While the CRA does not currently keep statistics related to the charities program for GBA Plus considerations, we continue to promote and support the application of GBA Plus. ... As such, during fiscal year 2022–2023, the program will seek training in GBA Plus for staff at various levels of the organization with a view to monitor and report program impacts by gender and diversity, and ultimately developing evidence-based policies and procedures that leverage considerations from a GBA Plus perspective. ... The following table shows the membership of each committee as well as directors’ committee attendance during 2021–2022, taking into consideration departures and appointments. ...

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. ...