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Archived CRA website

ARCHIVED - Non-Profit Organizations

The comments that follow are taken into consideration when making such a determination. ...
Archived CRA website

ARCHIVED - Losses on Shares on Which Dividends Have Been Received

These amendments relate to the dividends taken into consideration in determining the inventory value of a share that is not capital property. ...
Old website (cra-arc.gc.ca)

Mutual Agreement Procedure - 2012-2013 MAP Program Report

The views of the taxpayer, as presented in the MAP request, are given due consideration. ...
Old website (cra-arc.gc.ca)

Advance Pricing Arrangement - Program report - 2014-2015

At the close of the most recent fiscal year, 14 applications were under consideration for acceptance to the program (that is, instances where a pre-file meeting has occurred between the CRA and a taxpayer, but a taxpayer had yet to provide the submission). ...
Old website (cra-arc.gc.ca)

Mutual Agreement Procedure - 2013-2014 MAP Program Report

The views of the taxpayer, as presented in the MAP request, are given due consideration. ...
Old website (cra-arc.gc.ca)

Advance Pricing Arrangement - Program report - 2013-2014

At the close of the most recent fiscal year, 9 applications were under consideration for acceptance to the program (that is, instances where a pre-file meeting has occurred between the CRA and a taxpayer, but a taxpayer had yet to provide the submission). ...
Old website (cra-arc.gc.ca)

Mutual Agreement Procedure - 2014-2015 MAP Program Report

The views of the taxpayer, as presented in the MAP request, are given due consideration. ...
Old website (cra-arc.gc.ca)

TPM-16 - Role of Multiple Year Data in Transfer Pricing Analyses

Indeed, the use of inter-quartile ranges Footnote 6 is based on the assumption that the comparable transactions, whose observed financial outcomes are outside this range, are not comparable, simply on the basis of these observed outcomes rather than any consideration of the other economic characteristics of the transactions. ...
Old website (cra-arc.gc.ca)

Determination of 'activities engaged in by the person in the course of operating a public hospital' ...

If the hospital authority is a GST/HST registrant that provides taxable goods and services for consideration in the course of a commercial activity, then it will be subject to the usual rules under the GST/HST. ...
Old website (cra-arc.gc.ca)

Input Tax Credits for Holding Corporations and Corporate Takeovers

The financial advisory services provided by AdvisorCo involved its undertaking of a study to enable the rendering of an opinion as to the fairness of the financial consideration to be paid by PurchasingCo for the shares of TargetCo. ...

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