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The services provided by the lawyer and the articling student are considered legal services. 2. ... However, if a public service body supplies the legal services for a price that is equal to or more than the direct cost (not including the GST/HST and the Quebec Sales Tax (QST), when the person is a QST registrant) and charges an amount as GST/HST in respect of the supply, these supplies are considered to be taxable supplies. 24. ...

Where adjustments are being considered but the file will become statute-barred before the expiry of the 30-day representation period, the FR in consultation with the RTA should decide either to drop the proposed adjustment or to provide a representation period of less than 30 days. ... The adjustment should be considered material and approval should be obtained from the assistant director (AD) of SR&ED. ...

The CRM does not discuss procedures for a joint review as they are considered part of the more general coordinated review. ... If gross negligence penalties are considered, the FR and the RTA work together and inform their managers, prior to communicating with the claimant. ...

Programs* 3 3 0 100 Total 83 72 11 87 * All program branches share accountability for these commitments- Appeals, ACB, Customs, and PPB Legend: Appeals- Appeals Branch ACB- Assessment and Collections Branch ITB- Information Technology Branch FAB- Finance and Administration Branch HRB- Human Resources Branch PPB- Policy and Planning Branch CAEB- Corporate Audit and Evaluation Branch Appendix 3: Status of 2001-2004 action plan commitments Goal 1: Prepare managers to contribute to SD Items Descriptions Completed In progress Not started Dropped 1.1 Objective: Demonstrate leadership and commitment to SD 1.1.1 Recognize SD as a corporate value X 1.1.2 Finalize the SD policy X 1.1.3 Fully integrate SD into the business planning and reporting process to support the horizontal nature of SD X 1.1.4 Link our commitment to SD with appropriate messages in the CCRA Leadership Program X 1.2 Objective: Increase practice of balanced decision-making related to programs, policies, and operations 1.2.1 Develop and implement guidelines for integrating SD into the development of business plans and proposals to ensure that all aspects of SD are considered X 1.3 Objective: Raise the level of SD awareness; increase SD skills and knowledge 1.3.1 Develop/implement a SD learning strategy for management X 1.3.2 Review ongoing learning programs to identify SD awareness/training opportunities X 1.3.3 Provide managers with guidance material to support environmental stewardship and compliance X 1.4 Objective: Measure, monitor, and promote continuous improvement for SD results 1.4.1 Integrate SD considerations into key corporate management tools: 1.4.1.1 balanced scorecard 1.4.1.2 risk management policy 1.4.1.3 quality service initiative X 1.4.2 Perform periodic reviews of SDS implementation and report findings to senior management in conjunction with regular audit program X 1.4.3 Conduct a management review of the SDS 2001- 2004 and update the SDS for 2004-2007 X 1.4.4 Close significant gaps in the management and control system for the SDS in particular, documenting procedures and implementing a process for non-conformance and corrective action X Goal 2: Enable employees to contribute to SD Items Descriptions Completed In progress Not started Dropped 2.1 Objective: demonstrate leadership and commitment to SD 2.1.1 Create opportunities for employees to pledge commitment to SD X 2.2 Objective: Raise the level of SD awareness; increase SD skills and knowledge 2.2.1 Create and maintain opportunity for employees to share SD success stories, initiatives, and comments X 2.2.2 Provide employees with guidance material to help support environmental stewardship initiatives X 2.2.3 Encourage participation in CRA-endorsed initiatives, such as the annual commuter challenge (ongoing) X Goal 3: Green operations to contribute to SD Items Descriptions Completed In progress Not started Dropped 3.1 Objective: Demonstrate leadership and commitment to SD by continuing to develop and implement an environmental management system consistent with the ISO 14001 standard 3.1.1 Finalize CRA Environmental Policy X 3.1.2 Develop environmental management programs for all identified environment aspects: Procurement Paper Solid waste management Land use management Energy Water quality and conservation Fleet Ozone depleting substances X 3.1.3 Fully implement all elements of a performance measurement framework for: 3.1.3.1 Storage tanks 3.1.3.2 ODS management X 3.2 Objective: Increase practice of integrated decision-making related to programs, policies, and operations 3.2.1 Develop and pilot the use of SD guidelines for integrating SD into the development of operational resource proposals to ensure all aspects of SD are considered X 3.3 Objective: Measure, monitor, and promote continuous improvement 3.3.1 Develop/refine appropriate administrative systems to track performance on environmental and SD commitments X 3.4 Objective: Enhance or develop new partnerships to support shared SD objectives 3.4.1 Continue participation in interdepartmental committees, working groups and initiatives related to the environment and SD (ongoing) X 3.5 Objective: Meet or exceed federal environmental legislation and regulations and implement best management practices for environmental issues: 3.5.1 Procurement 3.5.1.1 Review/assess current Material Management Certification courses for green content X 3.5.1.2 Pilot green procurement training program with Headquarters' procurement officers; share results of pilot with others X 3.5.1.3 Introduce environmental specifications into National Individual Standing Offers X 3.5.1.4 Increase the number of clauses that give consideration to SD-green procurement into the contractual process, including selection criteria for Requests for Proposals (RFPs) X 3.5.2 Paper 3.5.2.1 Develop/revise procedures and standards to help reduce dependence on paper in internal operations: 3.5.2.1.1 Issue electronic document management standards X 3.5.2.1.2 Increase availability of forms, policies, and procedures on the Intranet (ongoing) X 3.5.2.1.3 Enhance and administer the protocol for submissions to the Agency Management Committee and Board of Management to help reduce paper use X 3.5.2.1.4 Implement an initiative to submit documents electronically to the National Archives/National Library X 3.5.3 Waste management 3.5.3.1 Divert an average of 50% solid waste from landfill in priority custodial facilities X 3.5.3.2 Implement best management practices for waste management including recycling at remaining custodial facilities X 3.5.3.3 Divert an average of 70% solid waste from landfill in priority leased facilities X 3.5.3.4 Integrate the requirement for contractor to provide waste reduction plans into all major construction, renovation and demolition projects in custodial and leased facilities (carry-over commitment) X 3.5.3.5 Implement best practices and initiatives related to the disposal (recycling/reusing) of obsolete or surplus goods: 3.5.3.5.1 Develop national disposal guidelines for publications no longer required 3.5.3.5.2 Review existing disposal guidelines for opportunities to integrate SD considerations 3.5.3.5.3 Assess/implement surplus uniform donations program X 3.5.4 Energy 3.5.4.1 Develop and communicate best management practices for energy efficiency X 3.5.4.2 Continue to participate in federal climate change initiatives (to be done in conjunction with the federal climate change initiative) X 3.5.4.3 Negotiate the inclusion of energy efficiency measures at leased facilities X 3.5.4.4 Implement energy and water conservation measures associated with the Federal Buildings Initiative (or other programs) when an energy assessment has demonstrated that it is cost-effective X 3.5.4.5 Incorporate energy efficiency measures, including the use of renewable energy alternatives, into major construction and renovation projects where feasible and cost effective with life-cycle payback X 3.5.5 Land use management Compliance assurance related to CEAA 3.5.5.1 Strengthen protocol to monitor/report on follow-up activities recommended by environmental assessment screening reports X Capital construction/renovation 3.5.5.2 Implement measures to "green" new capital construction projects (ongoing) X Compliance assurance with the Canadian Environmental Protection Act (CEPA): Storage tank regulation 3.5.5.3 Strengthen protocol to demonstrate compliance with CEPA's Federal Storage Tanks Regulation X Compliance with federal policy on contaminated sites 3.5.5.4 Strengthen protocol to demonstrate compliance with the federal policies for contaminated sites X 3.5.5.5 Assess and remediate contaminated sites consistent with best practices (ongoing) X 3.5.6 Ozone depleting substances (ODS) management 3.5.6.1 Manage inventories to reduce releases of ODS consistent with the Federal Halocarbon Regulations X 3.5.6.2 Implement management plan to convert / replace ODS inventories with alternative substances or technologies X 3.5.7 Fleet management 3.5.7.1 Reduce fleet emissions by increasing the number of alternative fuel vehicles in compliance with the Alternative Transportation Fuels Act (ATF) X 3.5.7.2 Continue reporting on compliance with the Alternative Fuels Act (annually) X 3.5.7.3 Co-ordinate fleet awareness training as opportunities arise through the government initiatives on climate change X 3.5.8 Water management 3.5.8.1 Strengthen protocol for water quality management X 3.5.8.2 Develop and communicate best management practices for water conservation X 3.5.8.3 Incorporate water conservation measures into major construction and renovation projects where feasible X 3.5.9 Hazardous substances management 3.5.9.1 Review hazardous materials management X 3.5.9.2 Develop strategies and action plans as required X 3.5.9.3 Strengthen protocol for Workplace Hazardous Materials Information System (WHMIS) X 3.5.10 Environmental emergencies 3.5.10.1 Strengthen protocol for environmental emergencies X Goal 4: Enhance programs to contribute to SD Items Descriptions Completed In progress Not started Dropped 4.1 Objective: Demonstrate leadership and commitment to SD 4.1.1 Explore ways to communicate our commitment to SD to clients, partners, and stakeholders and encourage their support X 4.1.2 Implement specific initiatives that help encourage compliance with Canadian laws, protect the health and safety of Canadians, and promote eco-efficiency: 4.1.2.1 Administrative Monetary Penalty System (AMPS) 4.1.2.2 Migrant health program 4.1.2.3 Pre-approval permit programs X 4.2 Objective: Increase practice of integrated decision-making related to programs, policies, and operations 4.2.1 Integrate SD into program management tools and practices: 4.2.1.1 negotiate inclusion of SD considerations in the Service Management Framework arrangements with provinces and territories to articulate CRA's commitment to SD 4.2.1.2 Incorporate SD in the CRA Business Development Strategy 4.2.1.3 Integrate environmental considerations into the Customs Self-Assessment initiative to reduce waiting times, trucks idling at borders X 4.2.2 Integrate consideration of SD into development of new program proposals and initiatives X 4.3 Objective: Measure, monitor, and promote continuous improvement 4.3.1 Explore ways to measure and report performance results of programs on all three aspects of SD X 4.4 Objective: Enhance or develop new partnerships to support shared SD objectives 4.4.1 Incorporate SD considerations into consultations with partners: 4.4.1.1.1 E-commerce conference 4.4.1.1.2 Memoranda of Understanding (MOU) with partners 4.4.1.1.3 Voluntary Sector Joint Initiative Action Plan 4.4.1.1.4 Annual consultation process X 4.4.2 Continue to work with other government departments in support of sustainable development: 4.4.2.1 Identify health and safety issues for trade and border compliance plan X 4.4.2.2 Harmonize customs procedures and electronic systems in support of Asia Pacific Economic Cooperation and Free Trade Area of the Americas trade facilitation initiatives X 4.5 Objective: Implement best management practices for environmental issues in program delivery: paper consumption procurement waste 4.5.1 Advance the use of electronic service delivery options and streamline paper-based transactions with the aim of reducing the use of paper: 4.5.1.1 Implement electronic service delivery options (ongoing) X 4.5.1.2 Implement the Correspondence Issue Management System (due March 31, 2005) X 4.5.1.3 Play lead role in global e-commerce industry by promoting e-filing and telefiling X 4.5.1.4 Negotiating the filing of RRSP listing to reduce need for paper filing X 4.5.1.5 Develop e-filing of objections through the Internet X 4.5.1.6 Develop Web-based training on blueprint initiatives X 4.5.2.7 Review forms and publications and expand use of Web site for distribution of information to clients X 4.5.1.8 Convert archival information onto software X 4.5.1.9 Reduce paper in charities tax package (T3010) by approximately 33% X Appendix 4: List of abbreviations AMPS Administrative Monetary Penalty System ACB Assessment and Collections Branch APEC Asian- Pacific Economic Coorperation AWICS Agency-wide Classification System BFTSO Burnaby-Fraser Tax Services Office Appeals Appeals Branch CAEB Corporate Audit and Evaluation Branch CAS Corporate Administration System CBSA Canada Border Services Agency CEAA Canadian Environmental Assessment Agency CEW Canadian Environment Week CIDA Canadian International Development Agency CIMS Correspondence Issue Management System CPB Corporate Business Plan CPE Customs Port of Entry EDM Electronic Document Management EMP Environmental Management Program EMS Environmental Management System EPPD Executive Personnel Programs Directorate ESS Employer Self-Service FAB Finance and Administration Branch FAST Free and Secure Trade FIHO Federal House In Order Initiative FPSCD Financial Policy Systems and Control Division HRB Human Resources Branch IMD Information Management Directorate MMD Materiel Management Directorate MSDS Material Safety Data Sheets MSS Manager Self-Service ITB Information Technology Branch OECD Organisation for Economic Co-operation and Development OPI Office of Primary Interest PATA Pacific Association of Tax Administrations PPB Policy and Planning Branch PWGSC Public Works and Government Services Canada PWRA Potable Water Risk Assessment RARD Revenue Accounting and Reporting Division SD Sustainable development SDS Sustainable development strategy SDGO Sustainable Development Government Operations SIMA Special Import Measures Act SMF Service management framework TPSD Telecommunications and Program Support Directorate TC Tax centre TSO Tax services office VSI Voluntary Sector Initiative WHMIS Workplace Hazardous Materials Information Systems WCO World Customs Organization Previous page Page details Date modified: 2017-06-22 ...

Normally, it is considered reasonable to assume that the profit element in any amount due is that proportion of such amount that the gross profit on the sale bears to the gross selling price; thus a reserve might be allowed equal to the full amount of the profit if no part of the selling price had been received. ... A claim for a reserve equal to the lesser of the gross profit on the sale and the amount due will not be allowed as it is not considered reasonable to assume that the vendor receives no profit until after the full investment in the property sold has been recovered. 13. ...

The courts have directed that connecting factors must be considered when making this determination. ... Note The central management and control of an organization is usually considered to be exercised by the group that performs the function of a board of directors of the organization. ...

The amount of the credit is considered taxable government assistance in the taxation year in which the qualifying co-op education work placement ends. ... The amount of the credit is considered taxable government assistance in the taxation year in which the credit is claimed. ...

However, with respect to stock dividends paid after November 21, 1985 other than stock dividends declared on or before that day, subsection 15(1.1) requires the fair market value of a stock dividend to be included in income, except to the extent that it is otherwise included in the recipient's income under paragraph 82(1)(a), where it may reasonably be considered that one of the purposes of the payment of the stock dividend was to alter significantly the value of the interest of any specified shareholder of the payer corporation. ... If the share portion of the dividend was not considered to be a dividend at the time it was paid (see 8 and 11 above), the cash portion will constitute "the full amount of the dividend" where that term appears in the Act. 25. ...

(Prior to May 23, 1985 loans that were not considered genuine (see IT-260R) were treated as transfers but this distinction is no longer necessary.) ... Where depreciable property is transferred to a related minor and the minor has other property of the same class as the property transferred, in computing the income or loss from the property attributed to the transferor (a) a reasonable portion of the capital cost allowance claimed by the minor in respect of the class (which portion may not exceed the maximum capital cost allowance that would be deductible in respect of the transferred property if the property were in a separate class) may be deducted, and (b) a terminal loss or recapture of capital cost allowance which arises and would otherwise be included in computing the income of the minor in respect of the class of depreciable property should be taken into account to the extent that such amount can reasonably be considered to relate to the transferred property. ...

An election filed with an amended return for the year will be considered invalid and will not be recognized. ... Where an election under paragraph 34(a) is in force at the time a sole proprietor, partnership or corporation disposes of or ceases to carry on a designated professional business or a part of that business and, at that time or some time thereafter, part or all of the work in progress in respect of which the election had been made is sold, subsection 23(3) provides that this work in progress is to be considered inventory notwithstanding that its value had previously not been taken into account in the annual determination of income. ...