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Current CRA website
Instructions for applying for a tax shelter identification number
Related persons are not considered to deal with each other at arm’s length. ... Where, for example, the only collateral for the debt is the tax shelter property itself, or potential income from that property, the $90,000 would be considered to be a limited-recourse amount. ... It also includes any other indebtedness of the person that can reasonably be considered to relate to the gift or monetary contribution if there is a guarantee, security or similar indemnity or covenant in respect of that or any other indebtedness. ...
Current CRA website
For discussion purposes only - Draft GST/HST Memorandum 3.7, Natural Resources
In addition, the meaning of mineral includes substances that are considered to be minerals within the ordinary meaning of that word. ... Jones is considered to be making a supply of a right to enter property for purpose of exploring for or exploiting a gravel deposit. ... Jones for the purchase of the gravel that is removed is considered to be a fee or royalty charged or reserved in respect of the right to explore for or exploit a natural resource. ...
Current CRA website
Frequently Asked Questions – 2021 Tax Implications of Phoenix payroll issues
Each claim will be considered on its individual merits and settled based on valid receipts and other supporting documentation. ...
Current CRA website
Passenger Transportation Services
A supply of a service of cancelling the ticket for that trip would therefore also be considered to be made in Newfoundland and Labrador and subject to the HST at a rate of 15%. ... Ride-sharing services are considered to be passenger transportation services. ... A person is considered to be making such supplies once the person starts providing commercial ride-sharing services, including commercial carpool services. ...
Current CRA website
Registered charities making grants to non-qualified donees
Meet the public benefit test: grant activities that do not meet the public benefit test would not be considered charitable. ... Generally, an unacceptable private benefit goes beyond what is considered to be charitable. ... However, the courts have stated that some activities that are charitable in Canada may not be considered charitable under Canadian law if carried out in a different country. ...
Current CRA website
Report #1 of the Advisory Committee on the Charitable Sector – January 2021
Data on Diversity The RFWG considered the question of the need for more data collection on the diversity of human resources in the sector. ... CRA Regulation of Earned Income and Business Activity During their deliberations, the RFWG and P&AWG both considered the question of regulation of earned income and business activity. ... It would advocate on behalf of these sectors when broader government policies are being considered, acting as a connector and communicator with other government departments. ...
Current CRA website
Recapture of SR&ED Investment Tax Credit Policy
The conditions are similar to those described in section 4.1 except that, in this case, all or part of the qualified expenditures can reasonably be considered to have been the subject of an agreement to transfer qualified expenditures. ... The asset will be considered to be converted to commercial use when it becomes available for use. ... Since the FMV of the property would reflect the costs of materials transformed into the property, the labour costs and a portion of the overhead expenditures, the FMV will usually be greater than the other limit to calculate (that is, the amount that can reasonably be considered to be included in computing the claimant's investment tax credit (ITC) in respect of the particular property that was acquired by the claimant). ...
Current CRA website
Informal Disclosure Guidelines
If the requester prefers to follow the formal process, then an informal request for the same information should not be considered or pursued. ... Information that does not directly or indirectly reveal the identity of the other party is not considered to be third-party information. ... The T2020 must be clear as to what factors were considered in making the decision to release the information, what information (if any) was redacted, and why the information was redacted. ...
Current CRA website
The 2016 RPP Practitioners’ Forum, Summary Report
The present value test in clauses 8503(2)(a)(ii)(E) and (F) of the Regulations would not apply since the indexation provided under the plan would not be considered a combination of indexation adjustments. ... Under subsection 147.2(8) of the ITA, the former employees of Employer A are considered to be former employees of Employer B since they are employees of a predecessor employer (as defined in section 8500(1)) provided that Employer B is considered to be a participating employer in relation to the pension plan. ... Otherwise, the plan would not be considered to be administered in accordance with the terms of the plan as registered. ...
Current CRA website
Chapter 10 - 8503(3) – Conditions Applicable to Benefits
The notice period is considered eligible service. Moreover, if instead of advance notice of termination the employee receives termination pay equal to the wages that the employee would have received during the notice period, the foregone notice period can similarly be considered eligible service. ... This is considered eligible service with an employer who participated in the plan under paragraph 8(e)(i) of IC72-13R8. ... Therefore, the re-purchase of this past service with new money would not be considered double-dipping. ...