Search - considered

Results 331 - 340 of 655 for considered

CRA assimilates a loan to a royalty agreement and finds that the principal advanced in fact was subject to GST/HST

6 November 2019- 11:58pm CRA assimilates a loan to a royalty agreement and finds that the principal advanced in fact was subject to GST/HST Email this Content CRA considered a situation in which a financing of a company with product sales was bifurcated into a non-interest-bearing loan and a royalty agreement. ...

S. 125(5.1)(b) passive income grind can be avoided by winding-up subs

However, in “this situation…GAAR must be considered” (see e.g., Iberville re using s. 85 to avoid rather than defer tax). ...

CRA confirms that the GST/HST test of an investment limited partnership is not a day-by-day numerical test

CRA stated that “we would likely conclude that the LP is not an ILP and further information would be required to determine if the LP … is considered an ILP at a later time. ...

CRA finds that a USA stripped away voting control of a parent over its wholly-owned subs

In CRA’s view, this then engaged ETA s. 128(4), which provides that for qualifying voting control purposes, a person is not considered to own shares if another person (other than a closely-related person) has voting rights over those shares described in similar terms to ITA s. 251(5)((b)(i), e.g., a “right under a contract … to control the voting rights attached to the share.” ...

CRA considers that a s. 107(2) rollout of Cdn Realtyco shares (i.e., TCP) to a NR-owned corporate beneficiary is inherently abusive

Such transfer was considered as an abuse of ss. 107(2), (2.1) and (5). ...

CRA finds that shares distributed out of an inter vivos trust on an active individual’s death were received as a consequence of death for s. 120.4(1.1)(b)(ii) purposes

S. 120.4(1.1)(b)(ii) was so engaged on the basis of a CRA position that that property received from an inter vivos trust, the terms of which unconditionally require that it distribute the property to the individual on the death of another person, can be considered as property acquired by the individual as a consequence of that person’s death. ...

CRA reaffirms that income derived from a prior year’s sale of an excluded business is not excluded from the TOSI rules

A, CRA indicated that any taxable dividends received by him are considered to be derived directly or indirectly from such investment business – so that, since he is not actively engaged in that business, such amounts will not be “derived directly or indirectly from an excluded business” of Mr. ...

Deshaies – Federal Court of Appeal criticizes the Federal Court for suggesting to CRA that it provide relief to a taxpayer

Boivin JA stated (at para. 7): [These] remarks … were ill-considered. ...

Stover – Federal Court requires CRA to think about waiving interest that accrued during a three-year delay in dealing with a late-filed Objection

Favel J considered it to be unreasonable for the CRA delegate not to take the three-year delay of CRA in responding to the Objection into account in considering the interest-relief request, so that the matter was “remitted to another Delegate for redetermination of the Applicant’s entitlement to relief from interest accrued due only to delays caused by the CRA.” ...

Loyer Succession – Federal Court allows review application for failure of CRA to consider a penalty-waiver agreement of the ARQ for the same unreported income

Before remitting the matter to another delegate for redetermination, LeBlanc J stated: [The estate] has the right to see the Agreement considered and to know why it was not applied in this case, if that was the CRA viewpoint. ...

You are here