Search - consideration

While it would not be the primary consideration in any eligibility determination, it could help provide additional context to the assessment process. ... But we flag this issue yet again, because it needs to be taken into consideration when the CRA is working on improved communications. ... They should not be cut off right away with no further assessment or consideration. ...

Its objective is to facilitate impartial reviews, open discussions, and ethical considerations surrounding the Agency's day-to-day business, including operational and personnel areas. ... Its objective is to facilitate impartial reviews, open discussions, and ethical considerations surrounding the Agency's day-to-day business, including operational and personnel areas. 2.2 Administration and management of the Discipline Policy HRB has functional responsibility for the administration of the Discipline Policy. ...

This is expected to deter serious non-compliance by communicating that tax evasion and fraud are criminal offences and offenders will be pursued and prosecuted. refine how it selects high-risk files by April 2016, taking into consideration regional, national, and international priorities. enhance its forensic and informatics capabilities by acquiring of tools and technological expertise needed for complex investigations by March 2017. increase co-operation with law enforcement agencies including, for example, an updated Memorandum of Understanding with the Royal Canadian Mounted Police. ... The Agency expects changes to the policy will strengthen security management, clarify roles and responsibilities, and include security considerations in delivering shared services, such as those provided by Shared Services Canada. ...

A promoter of a tax shelter includes a person who: sells or issues participating shares in the tax shelter promotes the sale, issuance, or acquisition of participating shares in the tax shelter acts as an agent or adviser for the sale or issuance of participating shares in the tax shelter acts as an agent or adviser to promote, sell, or acquire a participating interest in the tax shelter accepts consideration for his or her role in the tax shelter Example The CRA revoked the registration of Organization Z because, among other things, it promoted and provided private benefit to a tax shelter called TS Group. ... When an ineligible individual is a director, trustee, officer, or like official, or controls or manages a registered organization or applicant, the CRA may take the following into consideration in deciding the most appropriate course of action: What made the person an ineligible individual? ...

As described in subsection 7308(2), a retirement income fund is a qualifying retirement income fund at a particular time if the fund was entered into before 1993 and the carrier has not accepted any property as consideration under the fund after 1992 and at or before the particular time. In addition, a fund is a qualifying retirement income fund if the carrier has not accepted any property as consideration under the fund after 1992 and at or before the particular time, other than property from a retirement income fund that was a qualifying retirement income fund immediately before the transfer of property. ...

An individual may obtain a deduction under paragraph 60(l) in respect of all or part of amounts for the year they are included in the individual's income under subsection 146(8) to the extent they are paid (or in the case of a commutation payment received by a spouse as successor annuitant, to the extent it is directly transferred by the issuer of the RRSP) in the year or within 60 days after the end of the year: (c) as a premium under an RRSP under which the beneficiary is the annuitant; (d) to acquire a life annuity for the beneficiary or for the lives jointly of the beneficiary and the beneficiary's spouse, either with a guaranteed period that is not greater than 90 years minus the beneficiary's age or that of the beneficiary's spouse, at the time of its acquisition, or without a guaranteed period; (e) to acquire an annuity for the beneficiary for a term of years equal to 90 minus the beneficiary's age or, alternatively, 90 minus the age of the beneficiary's spouse, at the time of its acquisition; (f) to acquire an annuity under which a beneficiary child or grandchild (whether resident or non-resident), or a trust under which the child or grandchild is the sole person beneficially interested in all amounts payable under the annuity, is the annuitant for a term of years not exceeding 18 minus the age of the beneficiary at the time of its acquisition; or (g) to a carrier as consideration for a registered retirement income fund under which the beneficiary is the annuitant. ... Also, ¶ 27 indicates that annuity payments can be adjusted to (for example) take into consideration increases in the cost of living, and comments that a rollover to a registered retirement income fund is available. ¶ 28 is former ¶ 30 expanded to explain that a rollover is available when a subsection 146(8.91) election has been made. ¶ 29 is a general update of former ¶s 31 through 34 to reflect changes in the law discussed elsewhere in the bulletin and to reflect the change from a deduction to a non-refundable tax credit. ...

If requested to do so, consideration will be given to a waiver of the remuneration rule if the employer certifies that for the year(s) under consideration: insufficient company earnings prevented the payment of the above minimum remuneration; no dividends were declared or paid to connected persons; no increase in retained earnings of the employer occurred; no retained earnings of the employer were transferred to a related corporation. ...

The proposed changes provide for an increase in the maximum rebate currently available under the existing B.C. new housing rebate, and would only affect newly constructed or substantially renovated homes for which the consideration is over $525,000. ... As the HST is considered to be paid by the builder on or after April 1, 2012 and before April 1, 2013, if the individual satisfies the eligibility conditions for the existing B.C. new housing rebate, the individual would be entitled to receive an enhanced rebate of 4.47% of the consideration attributable to the building portion (excluding any amounts paid as rent) to a maximum rebate of $42,500. ...

Question 3 In applying clause XXIX A(2)(e)(i) of the treaty, will the CRA take into consideration both the direct and indirect relevant shareholdings in a tested company to determine whether 50% or more of the relevant shares of the tested company are not owned, directly or indirectly, by persons other than qualifying persons? ... In this respect, subsection 248(26) of the Act clarifies that an amount that a debtor becomes liable to pay (other than interest) as consideration for any property acquired by, or services rendered to, the debtor shall, for the purposes of applying the provisions of the Act, be considered to be an obligation issued by the debtor equal to the amount of the liability. ...

The taxable income for the previous tax year or for the last tax year in the preceding calendar year is calculated before taking into consideration the specified future tax consequences (see section 3.3) for that previous year. ... The taxable income in the previous tax year or in the last tax year ending in the preceding calendar year is calculated before taking into consideration the specified future tax consequences (see section 3.3) for that previous year. ...