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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. ...

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. ...

If there are multiple informal requests by the same requestor, for example during the course of an audit, consideration should be given to providing a consolidated response to the requests if appropriate. ... This means that, subject to the legislative provisions and other considerations identified in these guidelines for redacting certain information, especially related to an ongoing audit, the auditor, with the approval of their supervisor and that person's immediate supervisor, should be in a position to give the taxpayer or the authorized representative the requested information in response to an informal disclosure request. ... This consideration also applies to information in your Audit Plan. Once the test has been conducted, you may release the procedures. ...

The delegated manager must give consideration to the traveller’s circumstances, time constraints, personal safety, equipment to be carried and weather conditions. 5.7.3 Transportation expenditures related to having meals at a restaurant are not a reimbursable expenditure or allowance, as it is considered a personal expense. 5.7.4 Transportation: Air travel 5.7.4.1 Travellers must research and reserve flights with the Government Travel Service (GTS) through the Shared Travel Services (STS) portal as outlined in Business travel by plane on KnowHow. ... This includes but is not limited to: 5.7.4.5.1 advance seat selection fees including preferred seating, service fees for excess baggage/excess weight, and change fees for authorized modification of CRA business travel arrangements when supported by a written justification 5.7.4.5.2 airport improvement fees and airport departure tax not included in the prepaid airfare 5.7.4.6 When making air travel arrangements, consideration must be given to all factors impacted by fare and itinerary selection. ... The DCFO and DG, FAD must be included in the cc line. 5.16.6.2 The memorandum must include the background information, any considerations made, the summary of the consultation with the FSU and the FRAD Mobility Unit, and a recommendation. 5.16.6.3 The memorandum must include the sentence “The Finance and Administration Branch has been consulted and supports this exception.” 5.16.7 The DCFO and DG, FAD will review the memorandum for the exception request and provide feedback where applicable and brief the CFO and AC, FAB. 5.16.8 After obtaining the endorsement from the DCFO and DG, FAD, the ML 2 or higher, who is requesting the exception must finalize the exception request by signing the memorandum. 5.16.9 If it is a major exception, the ML 2 or higher, who is requesting the exception must: 5.16.9.1 route the draft memorandum to the CFO and AC, FAB for endorsement with a cc to the DCFO and DG, FAD 5.16.9.2 route the endorsed memorandum to the Commissioner’s office for approval with a cc to the CFO and AC, FAB and DCFO and DG, FAD 5.16.9.3 provide a final signed copy of the approved memorandum to the FRAD Mobility Unit 5.16.10 If it is a minor exception, the ML 2 or higher, who is requesting the exception must: 5.16.10.1 route the memorandum to the CFO and AC, FAB for endorsement with a cc to the DCFO and DG, FAD 5.16.10.2 provide a final signed copy of the approved memorandum to the FRAD Mobility Unit 6. ...

., 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. ...

The CRA will look to integrate gender considerations and findings of this initiative into its future planning and activities. ... Status ✓ 2019–20 Departmental Plan commitments Make sure all new initiatives take privacy considerations into account. ... This foresight exercise informed the Board’s consideration of its priorities for the years ahead. ...

Memorandum of Understanding TN-34 Computer software royalties TN-23 Concessions capital cost allowance IT-477(C) Condominiums capital cost allowance IT-304R2 direct ownership of units in Quebec, capital cost allowance IT-304R2 ownership IT-437R Congregation residence deduction IT-141R(C) Consideration disposition of property, without IT-460 Construction industries construction, defined IT-411R Containers capital cost allowance IT-472(SR) deposits, special reserves IT-154R Contests prizes, taxation IT-213R Contractors income computation IT-92R2 movable equipment, capital cost allowance IT-306R2; IT-469R Contracts annuity – see Annuity contracts- novation, taxation IT-334R2- payments for non-performance IT-467R2- receipts for non-performance, taxation of amounts IT-365R2- service, fees received for, taxation IT-334R2- types, tax implications IT-92R2 Control in fact impact of recent jurisprudence TN-32 Control of corporation income trust- change in trustees TN-38 Controlled corporations – see also Private corporations, Canadian controlled basic rules IT-64R4(C) change in control- investment tax credit IT-151R5(C)- loss utilization restrictions IT-302R3- related to change in executors, etc. of estates IT-302R3- scientific research and experimental development IT-151R5(C) control deemed not to have been acquired IT-302R3 control defined IT-64R4(C); IT-302R3 loss on disposition of property to IT-291R3 Convention expenses deduction from income IT-131R2 Convertible debt obligation redemption or cancellation- deemed to be an assignment TN-41 Part XIII tax TN-44 taxation on conversion TN-44 Tembec Inc. et al v. ... IT-288R2 inter vivos gifts to individuals or through trusts IT-209R(SR) legal and accounting fees IT-99R5(C) owned December 31, 1971- capital cost to testamentary trust IT-130 reduction of the cost government assistance IT-273R2 Property, cultural certified IT-407R4(C) deductions as gift IT-407R4(C)- official receipts IT-96R6 disposition to designated Canadian institutions IT-407R4(C) Property, depreciable acquisition date, effect on capital cost allowance IT-285R2 amalgamation of corporations IT-474R2 capital cost allowance- class 8 property IT-472(SR)- deductibility IT-128R clearing or levelling cost IT-485 disposition- combined consideration IT-220R2(SR) family farm transfer to child on death IT-349R3 legal and accounting fees IT-99R5(C) petroleum and natural gas activities IT-476R proceeds of disposition IT-220R2(SR) scientific research and experimental development IT-151R5(C) Property, ecological deduction as gift- official receipts IT-96R6 Property, eligible capital bad debts on sale of IT-123R4; IT-123R6 ceasing to carry on business IT-313R2 cumulative eligible capital calculation IT-123R4; IT-123R6 deceased person's IT-313R2 eligible capital amounts received on disposition IT-386R eligible capital expenditures IT-143R3 government rights IT-313R2 inter vivos transfer of farm property to child IT-268R3(SR); IT-268R4 legal and accounting fees IT-99R5(C) new system for calculation IT-123R6 replacement property IT-259R4 transactions, accounting for IT-123R4; IT-123R6 Property, foreign capital cost allowance IT-285R2 foreign tax credit re capital gains and losses IT-395R2 registered pension plans, special tax IT-412R2 Property, identical bonds, debentures, notes, etc. ... Treaty's Competent Authority Provision Thin Capitalization Imperial Oil and the Treatment of Foreign Currency Loans SIFT Rules – Transitional Normal Growth SIFT Entities – Definition of "Real Estate Investment Trust" in Section 122.1 Paragraph 251(5)(b) – Conditional Agreements CRA Auditors' Access to Audit Working Papers Foreign Entity Classification Application of Paragraph 95(6)(b) Pension Fund Corporations Application of Subparagraph 212(1)(b)(vii) Employee Stock Option Deduction Purchase Price Allocation for Rental Properties Subsection 78(4) – Liability Assumed by a Third Party Value of Company Attributable to Voting Non‑Participating Shares Criteria for Determining Hedge Effectiveness for Tax Purposes Definition of "Non-Portfolio Earnings" in Subsection 122.1(1) Filing Requirements for T5013, Partnership Information Return Transfer of GST/HST Refunds to Non‑Resident Security Accounts Anti-Discrimination Provisions Limited Liability Company under the Protocol TN-39 Settlement of a Shareholder Class Action Suit – Compensation by Way of Cash and Shares TN-40 Administrative Policy Changes for Taxable Employment Benefits TN-41 Eligible Dividend Designation – Subsection 89(14) The "More Than Five Full-Tine Employees" Test Meaning of "Business Rulings (Opinions) on Proposed Legislative Amendments Definition of "Tax Shelter" – Subsection 237.1(1) Donation of Flow-Through Shares – Subparagraph 38(a.1)(i), subsection 248(35) through (41) and section 237.1 Date-Stamping Procedures Conversion from Canadian GAAP to IFRS Exchangeable Debenture – Paragraph 20(1)(f) Convertible Debt Transfer Pricing and Dispute Resolution Stock Benefit Withholding Requirements Loss Consolidation and Provincial GAAR Provincial Income Allocation – Section 400 of the Income Tax Regulations Deductibility of Interest on Money Borrowed to Acquire Common Shares 5th Protocol to the Canada-US Tax Convention – Hybrid Entities 5th Protocol to the Canada-US Tax Convention – Limitation on Benefits Functional Currency Tax Reporting Rules TN-42 International Financial Reporting Standards (IFRS) TN-43 Taxation of Roth IRAs TN-44 Valuation of Special Voting Shares Key Employee Tax-Free Savings Account Corporate-Held Life Insurance Paid-Up Capital Increase by an Unlimited Liability Company Luxembourg Intermediary Payments by ULC Payments by a ULC to an LLC in 2009 Treaty Forms US LLC with a Canadian Branch Exchangeable Debentures: Paragraph 20(1)(f) Unanimous Shareholder Agreements and the CCPC Definition Cost of Property Acquired from a Shareholder for No Consideration Filings Based on Proposed Changes to Law Assessments Services Provided by a US Resident to a Canadian Subsidiary of a US Customer Services Provided by a US Employee to a Canadian Subsidiary Services Provided by a US Employee to a Customer of a Canadian Subsidiary IFRS and Foreign GAAP Loss Consolidation Foreign Currency Reporting Convertible Debentures: Paragraph 20(1)(f) Convertible Debentures and Part XIII Central Paymaster Rules Calculating LRIP for Cash-Basis Taxpayers Consistency in Audit Practice Update on Committees Foreign Exchange Gains and Losses Part 5 – List of cancelled and archived bulletins since the last publication of the index None Date modified: 2012-10-16 ...

Memorandum of Understanding TN-34 Computer software royalties TN-23 Concessions capital cost allowance IT-477(C) Condominiums capital cost allowance IT-304R2 direct ownership of units in Quebec, capital cost allowance IT-304R2 ownership IT-437R Congregation residence deduction IT-141R(C) Consideration disposition of property, without IT-460 Construction industries construction, defined IT-411R Containers capital cost allowance IT-472(SR) deposits, special reserves IT-154R Contests prizes, taxation IT-213R Contractors income computation IT-92R2 movable equipment, capital cost allowance IT-306R2; IT-469R Contracts annuity – see Annuity contracts- novation, taxation IT-334R2- payments for non-performance IT-467R2- receipts for non-performance, taxation of amounts IT-365R2- service, fees received for, taxation IT-334R2- types, tax implications IT-92R2 Control in fact impact of recent jurisprudence TN-32 Control of corporation income trust- change in trustees TN-38 Controlled corporations – see also Private corporations, Canadian controlled basic rules IT-64R4(C) change in control- investment tax credit IT-151R5(C)- loss utilization restrictions IT-302R3- related to change in executors, etc. of estates IT-302R3- scientific research and experimental development IT-151R5(C) control deemed not to have been acquired IT-302R3 control defined IT-64R4(C); IT-302R3 loss on disposition of property to IT-291R3 Convention expenses deduction from income IT-131R2 Convertible debt obligation redemption or cancellation- deemed to be an assignment TN-41 Part XIII tax TN-44 taxation on conversion TN-44 Tembec Inc. et al v. ... IT-288R2 inter vivos gifts to individuals or through trusts IT-209R(SR) legal and accounting fees IT-99R5(C) owned December 31, 1971- capital cost to testamentary trust IT-130 reduction of the cost government assistance IT-273R2 Property, cultural certified IT-407R4(C) deductions as gift IT-407R4(C)- official receipts IT-96R6 disposition to designated Canadian institutions IT-407R4(C) Property, depreciable acquisition date, effect on capital cost allowance IT-285R2 amalgamation of corporations IT-474R2 capital cost allowance- class 8 property IT-472(SR)- deductibility IT-128R clearing or levelling cost IT-485 disposition- combined consideration IT-220R2(SR) family farm transfer to child on death IT-349R3 legal and accounting fees IT-99R5(C) petroleum and natural gas activities IT-476R proceeds of disposition IT-220R2(SR) scientific research and experimental development IT-151R5(C) Property, ecological deduction as gift- official receipts IT-96R6 Property, eligible capital bad debts on sale of IT-123R4; IT-123R6 ceasing to carry on business IT-313R2 cumulative eligible capital calculation IT-123R4; IT-123R6 deceased person's IT-313R2 eligible capital amounts received on disposition IT-386R eligible capital expenditures IT-143R3 government rights IT-313R2 inter vivos transfer of farm property to child IT-268R3(SR); IT-268R4 legal and accounting fees IT-99R5(C) new system for calculation IT-123R6 replacement property IT-259R4 transactions, accounting for IT-123R4; IT-123R6 Property, foreign capital cost allowance IT-285R2 foreign tax credit re capital gains and losses IT-395R2 registered pension plans, special tax IT-412R2 Property, identical bonds, debentures, notes, etc. ... Treaty's Competent Authority Provision Thin Capitalization Imperial Oil and the Treatment of Foreign Currency Loans SIFT Rules – Transitional Normal Growth SIFT Entities – Definition of "Real Estate Investment Trust" in Section 122.1 Paragraph 251(5)(b) – Conditional Agreements CRA Auditors' Access to Audit Working Papers Foreign Entity Classification Application of Paragraph 95(6)(b) Pension Fund Corporations Application of Subparagraph 212(1)(b)(vii) Employee Stock Option Deduction Purchase Price Allocation for Rental Properties Subsection 78(4) – Liability Assumed by a Third Party Value of Company Attributable to Voting Non‑Participating Shares Criteria for Determining Hedge Effectiveness for Tax Purposes Definition of "Non-Portfolio Earnings" in Subsection 122.1(1) Filing Requirements for T5013, Partnership Information Return Transfer of GST/HST Refunds to Non‑Resident Security Accounts Anti-Discrimination Provisions Limited Liability Company under the Protocol TN-39 Settlement of a Shareholder Class Action Suit – Compensation by Way of Cash and Shares TN-40 Administrative Policy Changes for Taxable Employment Benefits TN-41 Eligible Dividend Designation – Subsection 89(14) The "More Than Five Full-Tine Employees" Test Meaning of "Business Rulings (Opinions) on Proposed Legislative Amendments Definition of "Tax Shelter" – Subsection 237.1(1) Donation of Flow-Through Shares – Subparagraph 38(a.1)(i), subsection 248(35) through (41) and section 237.1 Date-Stamping Procedures Conversion from Canadian GAAP to IFRS Exchangeable Debenture – Paragraph 20(1)(f) Convertible Debt Transfer Pricing and Dispute Resolution Stock Benefit Withholding Requirements Loss Consolidation and Provincial GAAR Provincial Income Allocation – Section 400 of the Income Tax Regulations Deductibility of Interest on Money Borrowed to Acquire Common Shares 5th Protocol to the Canada-US Tax Convention – Hybrid Entities 5th Protocol to the Canada-US Tax Convention – Limitation on Benefits Functional Currency Tax Reporting Rules TN-42 International Financial Reporting Standards (IFRS) TN-43 Taxation of Roth IRAs TN-44 Valuation of Special Voting Shares Key Employee Tax-Free Savings Account Corporate-Held Life Insurance Paid-Up Capital Increase by an Unlimited Liability Company Luxembourg Intermediary Payments by ULC Payments by a ULC to an LLC in 2009 Treaty Forms US LLC with a Canadian Branch Exchangeable Debentures: Paragraph 20(1)(f) Unanimous Shareholder Agreements and the CCPC Definition Cost of Property Acquired from a Shareholder for No Consideration Filings Based on Proposed Changes to Law Assessments Services Provided by a US Resident to a Canadian Subsidiary of a US Customer Services Provided by a US Employee to a Canadian Subsidiary Services Provided by a US Employee to a Customer of a Canadian Subsidiary IFRS and Foreign GAAP Loss Consolidation Foreign Currency Reporting Convertible Debentures: Paragraph 20(1)(f) Convertible Debentures and Part XIII Central Paymaster Rules Calculating LRIP for Cash-Basis Taxpayers Consistency in Audit Practice Update on Committees Foreign Exchange Gains and Losses Part 5 – List of cancelled and archived bulletins since the last publication of the index None Report a problem or mistake on this page Privacy statement The information you provide through this survey is collected under the authority of the Department of Employment and Social Development Act (DESDA) for the purpose of measuring the performance of Canada.ca and continually improving the website. ...