Search - considered

(c) Related party transactions The CRA is related in terms of common ownership to all Government of Canada departments, agencies, and Crown corporations and transactions between commonly controlled entities are considered inter-entity transactions. ... (f) Allowance for doubtful accounts An allowance for doubtful accounts is recorded where the recovery of account receivables and advances is considered uncertain. ... As a result, non-respendable revenues are considered to be earned on behalf of the Government of Canada and are therefore presented in reduction of the CRA's gross revenues. 5. ...

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. ...

Slide 7- Adequate books and records (2/2) Renee: In order to be considered adequate, books and records need to allow the CRA to verify: the charity’s revenue, including all charitable donations received; that the resources are spent on charitable programs; and that the activities themselves continue to be charitable We recommend that you keep all supporting documentation that relates to your revenue and expenses, and charitable activities. ... Books and records that are kept outside Canada, but are available electronically in Canada are not considered to be kept in Canada. ... This period also applies to donation envelopes, which as we mentioned earlier, are considered source documents. ...

It is our wish that the proposals and advice in this and the previous three submissions continue to be received and considered favourably. ... National inherent risk assessment working group (NIRAWG): The group considered the impact of the 2023 National Inherent Risk Assessment (NIRA) on the charitable sector by reviewing the policy by centering both the charitable sector and by using the Government's Gender-based Analysis Plus (GBA Plus) framework. ... Despite the limited number of focus groups and overall participants, their input was considered representative and aligns with ongoing discussions and government priorities identified by ACCS members, and with recommendations from previous ACCS reports. ...

For example, between countries, or within a country there may be wide variances in environmental and individual circumstances, such as: income wealth education health social opportunities economic opportunities the cost of basic necessities of life and simple amenities geographic location (between countries, or even within a country) Such particular environmental and individual circumstances should be taken into considered when developing criteria and processes for determining whether a person is experiencing poverty. 3. ... A charitable benefit that relieves poverty can: take many different forms vary greatly between countries, or within a country vary over time Example of a charitable benefit that relieves poverty that varied over time The following is an example of a charitable benefit that relieves poverty that varied over time: providing access to the internet to help with job searches In the past, this was not considered a charitable benefit that relieves poverty. ... Therefore, it is possible that in some situations providing assistance through counselling or by other means to individuals in serious financial trouble may be considered to be relieving poverty, even if the individuals are not then destitute [...] ...

Changes in use of capital property that are insignificant are not considered to be changes in use for the purposes of the Act. ... Where such changes of less than 10 per cent accumulate to 10 per cent or more, the accumulated changes are considered to be a significant change, invoking the change in use rules. ... The registrant is considered to have sold the computer at its fair market value at that time. ...

A taxpayer requesting an interpretation should provide sufficient information to enable the CRA to understand the issues to be considered. 12. ... Circumstances in which the CRA may not issue a ruling include when: a transaction on which a ruling has been requested is the same in character as a transaction completed by the requestor in a prior period, and the application of the relevant legislation to the earlier transaction is under discussion with the requestor, in dispute, or under assessment or proposed assessment, but is not before the courts; the CRA believes that the request may be in respect of illegal activities; a request concerns a matter in respect of which a notice of objection filed by the requestor is being considered; the central issue involves a matter that is before the courts or, if a judgement has been issued, when an appeal to a higher court is being considered; a request contains alternative courses of action on the part of the person requesting the ruling; a request is for a determination of the fair market value of property; a request involves a matter dealing with proposed or draft legislation, draft regulations, budget proposals, or notices of ways and means motions; a request concerns tax, duty, or charge-related calculations (for example, the amount of net tax due for GST/HST purposes or the amount of excise duty payable); a ruling would require an opinion on generally accepted accounting principles or commercial practices; a request is for a determination of fact, and the circumstances are such that all of the pertinent facts cannot be established (this could include issues involving the carrying on of a business, the existence of a partnership, a trust or an agency relationship, or the reasonableness of a cost allocation method); or a request is for the interpretation of a law not administered by the CRA (for example, a foreign law). 31. ...

Consideration is considered to be "paid" when the supplier receives the money, property or service which is consideration for the supply. ... Under this broad definition, any record of a supply which sets out the goods or services which make up the supply, along with the consideration due or paid for the supply, will be considered to be an invoice. ... Where a person gives a deposit in respect of a supply, (other than an amount in respect of a covering or container in respect of which section 137 applies to deem the covering or container to be part of the property supplied), that deposit is not considered to be consideration for the supply unless and until the supplier applies the deposit against the consideration for the supply or the deposit is forfeited. 43. ...