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This additional time is at the discretion of the tax services office where the disclosure is being considered. ... In general, the supply of one or more individual assets will not be considered to be the supply of a business. ... As a result, the legal services would not be considered to be in respect of real property situated in Canada. ...

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). ...

On this basis, the individual is considered a patient of the facility and the physician’s services are considered rendered to that patient. ... On this basis, the individual is considered a patient of the facility and physician B’s services are considered to be an institutional health care service rendered to that patient. ...

As such, partnership property is considered to be for use by the partnership in its commercial activities, and is not considered to be for use of the partner in the partner's commercial activities. ... (b) What factors are considered in deciding whether or not to bump an appeal? ... (f) A client has to initiate the disclosure for it to be considered voluntary. ...

CCRA Comments A customer list is considered to be intangible personal property. ... In the past, we have considered situations with the following characteristics. ... Q.36- Dutiable Royalties Please provide concrete examples of royalties considered dutiable. ...