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The Agency is strengthening its governance over learning through the introduction of new directives and guidelines that will be considered by the Board at its meetings in June. ... Response In 2008-09, the internal mobility rate (including promotions, transfers and lateral moves) was of 21. 6% in the CRA a level considered to be indicative of sound learning and development. ... Key Questions 1: What processes are in place to ensure that the workplace is safe and that employees' health and wellness are being considered? ...

More specifically, it applies where a person or partnership acquires or disposes of shares of the capital stock of a corporation or interests in a partnership, either directly or indirectly, and it can reasonably be considered that the principal purpose for the acquisition or disposition is to permit a person to avoid, reduce or defer the payment of tax or any other amount that would otherwise be payable under the Act (referred to in this article as a “tax benefit”). ... The words of paragraph 95(6)(b) are broad and could be considered to apply to a wide range of transactions. ... For example, even though a purpose of the person making a share acquisition may be to earn a return on that investment, if a tax benefit is enjoyed by another person by virtue of the share acquisition, the acquisition may nevertheless be considered to have been made principally for the purpose of creating the tax benefit. ...

In making a determination of whether or not a PE exists, there are numerous factors to be considered that are outlined in the OECD Model Commentary and derived from jurisprudence. ... Taking a different view could result in only the headquarters of a business ever being considered a PE and this would generally defeat the purpose of Article 5 (Permanent Establishment) and Article 7 (Business Profits) of our treaties since the headquarters of a business are generally located in the state of residence of the person carrying on the business. ... The discussion above is only intended to provide some examples of factors that could be considered. ...

A Crown charge does not include a tax or any portion of tax that may reasonably be considered to be a municipal or school tax or any amount prescribed in section 1211 of the Regulations. ... (e) If an operator of a Canadian resource property disposes of production from that operation to the Crown, and simultaneously or subsequently acquires production from that operation from the Crown for an amount that exceeds its fair market value, subsection 69(7) applies to deem the acquisition to be at fair market value as determined under subsection 69(9) (see 11 and 16 below), and if the disposition to the Crown was made at less than fair market value, subsections 69(6), 69(8) and 69(10) are not considered to apply to that disposition. ... When the specific conditions in subsection 69(9) exist, that is, when there is a disposition to and a buy back from the Crown of a particular quantity of production by the producer, subsections 69(6), 69(8) and 69(10) are considered not to apply to the disposition to the Crown if that disposition was made at less than fair market value. ...

However, if the taxpayer's legal representative applies in writing within that period to the Director of the local Revenue Canada tax services office, an extension of the period to what is considered reasonable in the circumstances may be granted. ¶ 5. ... If a gift is described in two or more of the categories of "total charitable gifts," "total Crown gifts," "total cultural gifts" or "total ecological gifts" made after February 27, 1995, it will be considered in the following order: a cultural gift, an ecological gift, a Crown gift, and a charitable gift. ¶ 8. ... The reader should, therefore, consider such comments in light of the relevant provisions of the law in force for the particular taxation year being considered, taking into account the effect of any relevant amendments to those provisions or relevant court decisions occurring after the date on which the comments were made. ...

Cured fish – Fish and fish products identified as follows: salted groundfish, smoked and pickled herring, pickled mackerel, pickled turbot, pickled and salted alewives, pickled trout, and other pickled fish products cod oil and cod livers Designated employer – A person who is considered to be the employer of self-employed fishers. ... "Type 1" fisher – a member of the crew who either: owns or leases the boat or specialized fishing gear used to make a catch employs other persons under a contract of service to make a catch "Type 2" fisher – any self-employed fisher who is not considered "type 1. ... Your return is considered on time if we receive it or if it is postmarked on or before the next business day. ...

All comments received by August 31, 2008, will be considered. New guide for ethnocultural groups now available on our Web site Charitable Work and Ethnocultural Groups ‑ Information on registering as a charity – http://www.cra-arc.gc.ca/tx/chrts/plcy/thn-eng.html. ... Funding is available to registered charities and non-profit organizations serving the charitable sector in Canada to support projects designed to: improve the capacity of the sector to develop and deliver sustainable compliance based education programs; increase the capacity of the charitable sector in meeting regulatory compliance requirements in a sustainable fashion; and raise awareness among the charitable sector of regulatory obligations under the Income Tax Act. 2008/09 funding priorities: Projects designed to address the distinct needs of small and rural charities in meeting their obligations under the Income Tax Act will be considered for possible funding. More specifically, innovative projects designed to address one, or more, of the following priorities will be considered: Projects that focus on the development of tools designed to assist small and rural charities in locating and/or accessing local, regional, and/or provincial information/resources intended to support charities in meeting their regulatory obligations under the Income Tax Act; Projects with broad national application designed to raise the awareness and capacity of boards of directors regarding their compliance obligations under the Income Tax Act; and Projects that foster collaboration with other registered charities to increase the ability of small and rural charities to meet their obligations under the Income Tax Act. ...

The recommendations by the JRT deal with some of the most salient areas of federal charity regulation and will be considered seriously and speedily. ... This will not be considered if a registered charity changed its focus after registration to non-charitable activities, or if the request is solely based on the charity no longer wanting to be registered. ... In the case of consolidations, all original bodies are considered to undergo voluntary revocation. ...

In cases where a supply is made for more than one purpose, all of the purposes would be considered when determining if the supply is a qualifying health care supply. ... Every combination of eligible corporations or eligible Canadian partnerships whose names appear in Part A of the form (and on any attached page) is considered to have made the election. ... Licensees’ returns must be filed up-to-date to be considered for semi-annual filing. ...

GST/HST issues Generally, fundraising by its very nature is considered a profit activity. Organizations that are established and operated for the sole purpose of raising funds are not considered non-profit organizations for GST/HST purposes, even if all the profit from a fundraising activity is donated to a registered charity. ... Income tax issues As previously mentioned, fundraising by its very nature is generally considered a profit activity. ...