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Note that all requirements must be met under the ITA to be considered a designated member for the purpose of the assignment and similarly for the allocation of the business limit from the partnership and those requirements have not been considered in the response. ... The issue will be considered further and discussed with our Publications staff in HQ. ... A transcript faxed subsequent to the original processing review response often is not considered, either. ...

CRA has considered whether its Large Business compliance approach is in line with a cooperative compliance regime and whether we should introduce a formal pre-filing review program. ... Are any initiatives being considered by the CRA to improve the corporate tax assessment process in the ITSO? ... When a subsidiary corporation is wound up into a parent corporation, it ceases to exist as a legal entity and cannot be considered part of the parent corporation. ...

The creation of a separate telephone enquiries line for representatives is not being considered at this time. ... Adding additional filtering options may be considered for future enhancements. ... If the return was fled by October 1, it was considered to have been fled on time. ...

In a scenario where the corporation has income from the provision of services and from income from non-services, the two should generally be computed separately, and the non-service income considered in determining if the requirement of the definition is met. ... Subpart F income is not deemed to be income under Canadian domestic law, and thus would not be considered to be U.S. ... Subsection 75(2) of the Act applies so that the income of the alter ego trust is considered to be the income of the Settlor, who created the trust and who is, under the trust, a lifetime beneficiary. ...

Respecting the tests in s. 20(1)(c)(ii), it might be considered that the note was consideration for property acquired. ... In any other assessment, GAAR likely would be applied as the double-utilization of the SIOH would be considered to be abusive. ...

c) If this constitutes construction of a residential complex, would 5, or only the 1 additional unit, be considered to be constructed? ... Since NewCo is not considered to have constructed or substantially renovated the residential complex, it is not considered a builder for the purpose of paragraphs (a) nor (b) of the definition of “builder” in subsection 123(1). ... In this case, the coupon is not considered to be for a fixed dollar amount. ...

Has the CRA considered the entity classification for Luxembourg limited partnerships or special limited partnerships? ... Because Gabon and Ivory Coast are civil law jurisdictions and Quebec has a civil law system, it was considered appropriate to compare the characteristics of those foreign entities to the characteristic of partnerships formed under the Civil Code of Quebec. ... These are general conclusions, but every arrangement needs to be considered on its own merits. ...

Question Where non-residents affected by the new GST/HST remote seller rules, that need to confirm the purchaser’s GST/HST registration number, what evidence will be considered satisfactory to satisfy the Minister that the non-resident seller obtained a particular number? ... The possible answers seem to be: (a) The AII will be available on the entire cost of the asset on its completion – it is considered “acquired” in its entirety only when it is completed (b) The AII will not be available if construction of the asset commenced prior to November 21, 2018 – it was considered “acquired” when construction commenced. ... (d) Some other possibility not considered above. Can the CRA confirm how the rules will apply for assets under construction? ...

In the above scenario, what parties would be considered NR1 and NR2, respectively, and what are their reporting obligations under subsection 237.4(4)? ... We often refer to a “90%” rule, but neither CRA nor the courts have ever considered 90% to be a strict threshold. ... Subsection 55(2) applies such that, for purposes of the Act, the deemed dividend is considered not to be a dividend and to be proceeds of disposition of the share. ...

However, where the seller is a partnership, the CRA looks at the partners on the basis that the partnership is not considered to be a person under s. 96 for purposes of s. 116. ... U.S. resident considered to derive Canadian-source dividends for purposes of the Canada-U.S. ... In response to the two questions, whether rulings or audit guidance can be provided or shared about files where the anti-avoidance rule has been considered, there is no such file. ...