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CRA Response to Q.9(a) The Supreme Court of Canada considered the concept of profit in Canderel Ltd. v. ... That part will be considered to be the amount which is reasonable in light of the circumstances. ... The CRA is of the view that a “5 to 7” or a team lunch of a social nature could be considered as a type of social activity. ...

All interest payments would then be considered to be “participating debt interest” as of the time a contingent or dependent amount is paid or payable. ... Where a debt bears only simple interest, any accrued and unpaid simple interest itself will not be considered to be an outstanding debt to a specified non-resident. ... In the situation submitted, the determination not to make an election will generally not be considered to have been made using reasonable efforts. ...

Notes from Presentation Trade receivables generally would be considered to arise in the ordinary course of business. ... Treaty, CRA has considered many strategies designed to ensure that either Art. ... CRA position CRA considered the fixed base PE provision in para. (1) of Art. ...

The legislation requires the calculation of income that could reasonably be considered to contribute to the capital gain. ... The question to be asked is, what is the amount of income that would be considered to contribute to the gain? ... Thus, only a portion of that income could constitute the safe income that is considered to contribute to the gain. ...

S. 94(2)(t) applies to expunge the contribution after the time of sale, so that thereafter, the contribution is considered to have never occurred. ... If this test is satisfied, then the business is considered an Excluded Business and the TOSI rules do not apply by virtue of the amount being an Excluded Amount. ... CRA concluded that the specified individuals could be considered to be actively engaged. ...

However, travel between RPEs is considered employment-related. It is a question of fact whether a particular location is considered a RPE. ... (b) Home office A home office may be considered an RPE of an employee. ... Relief from a gross negligence penalty assessed under the Act can be considered under subsection 220(3.1). ...

Where the election is not included with the income tax return filed, the election is considered late. ... Is the trust considered not to deal at arm’s length with Parent such that paragraph 43.1(2)(b) will apply? ... If an individual is not considered a factual resident of Canada, they may still be considered a deemed resident under s. 250(1). ...

Q.18(b) Is efiling of T4s and T5s being considered by CRA, instead of web uploads of.XML files? ... If so, which forms are being considered for the use of electronic signature? ... Q.20(d) How should a taxpayer handle GST (or HST) when selling NFTs that are considered inventory? ...

Taxpayers who do not engage in abusive transactions. maintain an effective tax control framework. and are open and transparent with the CRA, are considered low-risk. ... Those that push the envelope and engage in abusive tax avoidance, for example, are considered higher-risk from a non-compliance perspective. ... Factors that may be considered include the level of non-compliance, large unexplained tax reserves, and potential tax at risk. ...

Would its principal business be considered to be lending, and would income tax concepts be applied so that it would be considered to be earning income from property rather than having a business. ... Although revenues received by a person are considered in determining the principal business of the person, they are not the only factor that will be considered and is not itself a determinant factor. ... Comments from the CBA will be considered in the context of this review. ...