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Old website (cra-arc.gc.ca)

Small Producers of Wine

[Wine licensees are considered to be "small producers" of wine for a fiscal month in a particular fiscal year if: their total sales of wine packaged in Canada during the previous fiscal year did not exceed $50,000, and their total sales of wine packaged in Canada during the particular fiscal year, before the fiscal month, did not exceed $50,000.] ... For excise duty purposes, wine will be considered produced at the point where it has completed initial fermentation. ... For the fiscal month of July 2003, the licensee is considered to be a small producer because the 2002 calendar year sales and current calendar year (2003) sales did not exceed the $50,000 threshold. ...
Archived CRA website

ARCHIVED - Canada Council Grants

In addition, payments made for the purchase of works of art from a self-employed artist under the Art Bank program of the Council are not grants but are considered to be ordinary business income to the artist; accordingly, such payments are included in the income or loss under section 9. ... When a taxpayer receives an amount by virtue of or in connection with an office or employment, it is considered employment income under subsection 5(1). ... In another case when, for instance, an artist is selected by the Council for training or development through an arrangement under which the artist is placed under an employer for a small salary or no salary while the Council subsidizes the artist's employment income, the assistance from the Council to the artist, whether paid directly or through the employer, is considered to be received by virtue of the employment, and is therefore taxable in the artist's hands as income from employment. ...
Archived CRA website

ARCHIVED - Income of contractors

In less formal situations where no construction contract exists or where the terms of a contract do not require formal approval of progress billings by the purchaser's architect or engineer before payment, the amount thereof, net of holdbacks if any, will be considered to be receivable and includable in the contractor's income as of the date such billings are made. 4. ... In contrast to 7 above, a cost is not considered to have been incurred in the performance of a contract in the year and is not deductible in the year in accordance with the comments in 6 above when it is, for example, (a) the cost of materials that have been merely ordered for future delivery, (b) the cost of materials and supplies that are described in a contractor's inventory, as that term is defined in subsection 248(1), including those earmarked for a specific contract but not delivered to the job site, (c) a holdback withheld by a contractor from a subcontractor if the contractor's liability to the subcontractor in respect thereof has not been established by the issuance of a required certificate by an architect or engineer, or (d) the gross amount of a billing rendered by a subcontractor to a contractor that requires, but has not received, approval prior to payment. 9. ... Where a person obtains a contract and agrees to sell to another person the right to carry out or complete the contract, the amount received on the sale is regarded as being in lieu of the profits expected to be earned had the contract been carried out in full, and therefore the amount is considered to be income. ...
Old website (cra-arc.gc.ca)

Harmonization of Sales Taxes of Prince Edward Island and De-Harmonization of Sales Taxes of British Columbia Audit

Conclusion: The enhancements relating to the new accounts created for PEI were considered to be appropriate and mapped to the correct RL accounts. ... Based on our sample review of the applicable changes, the enhancements relating to the new accounts created for PEI were considered to be appropriate. ... Conclusion The enhancements relating to the new accounts created for PEI were considered to be appropriate and mapped to the correct RL accounts. ...
Old website (cra-arc.gc.ca)

Unpaid Municipal Taxes and Redemption by the Previous Owner

Thus as stated above, because there in Québec is a possibility that the previous owner will redeem the property within a prescribed time period following the auction sale and because of the effect of the redemption, the issue is whether in that province the auction sale can be considered a supply for GST purposes. ... B is considered to be selling the land back to Mr. A for $ 53,500 plus interest. ... B is considered to be selling the land back to Co. A for $ 100,000 plus interest. ...
Old website (cra-arc.gc.ca)

Meaning of the Phrase Establishing a Business Venture in Canada

" In effect, activities or undertakings included in the definition of "business" in subsection 123(1) would also be considered activities or undertakings in the course of a "business venture. ... The company now has Canadian clients, but all business is conducted in the USA and Kruks Inc. is not considered to be doing business in Canada. 3 Kruks Inc. will incorporate this business in Canada (separate from its own corporation) before the actual commencement of business operations. 4. ... Even if the Consortium purchased real property in Canada, it is the Consortium's view that it would not be considered resident under subsection 132(2) of the Act since no supply will be made through the property at that point in time. ...
Old website (cra-arc.gc.ca)

Trade Unions and Similar Employee Associations

An entity must meet all of the conditions set out in this definition to be considered a non-profit organization for the purposes of the Act. ... A non-profit organization is considered to have been "established primarily for the benefit of organized labour" if it was established primarily to provide some advantage to organized labour, such as: a trade union as defined in section 3 of the Canada Labour Code; a trade union as defined in any provincial act that provides for the investigation, conciliation, or settlement of industrial disputes; an association of public servants whose primary object is to promote the improvement of the members’ conditions of employment or work; or a parity or advisory committee or similar body. 15. ... Therefore, Organization A is considered to have been "established primarily for the benefit of organized labour". ...
Old website (cra-arc.gc.ca)

Refund, Adjustment, or Credit of the GST/HST under Section 232 of the Excise Tax Act

An early payment discount to which section 161 applies is not considered to be a reduction of consideration. 10. A reduction in consideration is not considered to have occurred if the goods are sold back to the original supplier. To be considered a reduction of consideration, it must be evident that the goods are being returned to the supplier rather than being sold to the supplier. ...
Old website (cra-arc.gc.ca)

RPP Practitioners' Forum - 2009

Although other methods may be considered to be reasonable, the Registered Plans Directorate (RPD) considers the following method to determine the estimate of the MP offset to be reasonable: MP offset = MP account / Factor MP account = value of the individual's MP account at the time of transfer; and Factor = (B x C) / D Where B = applicable present value factor at the time of transfer C = the lump sum value of the individual's total lifetime retirement benefit entitlements before MP offset D = prescribed amount of the individual's total lifetime retirement benefit entitlements before MP offset Other methods will be considered on a case by case basis. ... To be considered as pensionable service, a period of time must first qualify as a period of eligible service under the Act. ...
Old website (cra-arc.gc.ca)

RPP Consultation Session - Questions from the Industry November 30, 2005

The impact of disallowing contributions and forcing the refund of the amount out of the plan, and into income, is not considered double taxation under subsection 248(28) of the Act. ... A deemed registered pension plan is considered to be a registered pension plan (except for purposes of paragraphs 60(j) and 60(j.2) and subsections 147.3 and 147.4 of the Act) in accordance with subsection 147.1(3) of the Act. ... Our present policy requires that, in order for a request to be considered, there must be written evidence of the provincial regulator requirement to segregate accounts in the particular circumstances. ...

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