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Therefore, we would suggest that your concerns on this matter should be sent to the Minister of Finance for his consideration. ... Are there other considerations that apply to a determination of whether Employer B's contributions/payments would be considered eligible contributions under subsection 147.2(2) of the ITA assuming conditions in subsection 147.2(2)(a) are otherwise satisfied. ...

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. ...

Claim preparer (for the purposes of claim preparer information) A claim preparer of an SR&ED form means a person or partnership who agrees to accept consideration to prepare, or assist in the preparation of, the form but does not include an employee who prepares, or assists in the preparation of, the form in the course of performing their duties of employment. ... 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 for that previous year. ...

Services provided without charge by other government departments and inter-entity transfers of tangible capital assets for nominal or no consideration are recorded and measured at the carrying amount. ... The amount to be paid in respect of the cases identified as likely to be lost has been recorded in accounts payable and accrued liabilities, based on the current best estimate of the consideration required to settle the present liabilities at the end of the reporting period, taking into account the risks and uncertainties surrounding the liabilities. ...

Certain services received on a without charge basis, including inter-entity transfers of tangible capital assets for nominal or no consideration, are recorded at the carrying amount. ... The amount to be paid in respect of the cases identified as likely to be lost has been recorded in accounts payable and accrued liabilities, based on the current best estimate of the consideration required to settle the present liabilities at the end of the reporting period, taking into account the risks and uncertainties surrounding the liabilities. ...

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. ...

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? ...

Given the scope and importance of topics addressed by this assessment, development of responses requires careful consideration and internal discussions that will take time. ... While the CRA possesses the appropriate drivers of performance for an “A” score, public opinion research shows that timeliness is an important consideration in determining the ‘workability’ of a dispute resolution mechanism. ...

Philip Lawrence (CPC) again asked why SINs were not used and what the OAG’s considerations were on that; the OAG noted it was a policy choice related to the speed of getting the CEWS support out. ... Nevertheless, the CRA’s decision was made by balancing several important considerations: Timeframes and technology capability: Building a system to collect SINs, cross match them to employer accounts and manage which ones were getting benefits for which companies during which period would have been complex and taken a significant amount of time to build. ...

Each 5-year period can be with more than one employer In addition to the foreign service provisions set out in Newsletter No. 93-2, the CRA will give favourable consideration for the transfer of funds from a foreign pension plan to an RPP under subparagraph 8502(b)(v) of the Regulations, in order to allow the foreign service to be recognized under subparagraph 8503(3)(a)(v), when the following conditions are satisfied: The foreign pension plan is situated in a country that imposes an income tax and the plan qualifies for an exemption from tax, a reduced rate of tax or other favourable tax treatment that is provided under the laws of that country for pension plans. ... MEPs Where the plan is a MEP (including SMEPs), it is not necessary to take into consideration benefits payable under other plans. ...