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Old website (cra-arc.gc.ca)

Residential Real Property - Rentals

The property taxes are considered part of the consideration for the rental of the property. ... Under certain conditions, the supply of a residential unit that is supplied on a rent-geared-to-income basis is considered to be a supply of a municipal service, and once the supplier has been designated as a municipality for the purposes of the municipal rebate, the organization is entitled to claim the rebate. ...
Old website (cra-arc.gc.ca)

Director's Liability

The circumstances must be considered against an objective standard of a “reasonably prudent person.” ... Following an initial investigation, the CRA will inform, in writing, the directors who may be liable that one or more assessments under section 227.1 of the ITA, section 323 of the ETA, section 81 of the ATSCA, section 295 of the EA2001, or section 95 of the SLPECA are being considered. 20. ...
Old website (cra-arc.gc.ca)

Non-resident employer certification

In the case of an employer that is not a partnership: A qualifying non-resident employer at any time means an employer that is at the time of the payment certified by the Minister of National Revenue under subsection 153(7) of the Income Tax Act and is either resident in a country that Canada has a tax treaty with, or would be considered resident in a country that Canada has a tax treaty with, if that country treated the employer as a corporation for tax purposes (e.g., a limited liability company formed in the U.S. that has not elected to be treated as a corporation for U.S. tax purposes). ... Since the non-resident employee will be paid for only 10 working days in Canada for 2016 they meet the less than 45 working days in a calendar year condition so they are considered a qualifying non-resident employee and the QNRER will not be required to withhold tax from the employee’s remuneration for the services provided in Canada during 2016. ...
Archived CRA website

ARCHIVED - Deemed Disposition and Acquisition on Ceasing to be or Becoming Resident in Canada

Where this is the case, the person is considered to have become so resident at the commencement of that year and to have ceased to be so resident at the end of the year so that the provisions of section 48 apply. ... Where the taxpayer is a trust, the trust is generally considered to become resident or cease to be resident in Canada when the trustee who has ownership or control over the assets of the trust becomes or ceases to be resident. ...
Old website (cra-arc.gc.ca)

Guidelines for Taxpayers Requesting Treaty Benefits Pursuant to Paragraph 6 of Article XXIX A of the Canada-U.S. Tax Convention

Article XXIX A contains provisions designed to prevent residents of third countries from securing benefits of the Convention through structures and arrangements that are considered to give rise to "treaty shopping". ... A Request will not be considered complete if supporting rationale is not offered or other required information is not provided. ...
Old website (cra-arc.gc.ca)

TPM-16 - Role of Multiple Year Data in Transfer Pricing Analyses

Although the above discussion explains that using multiple years of data can increase knowledge about the relevant economic characteristics of transactions being considered as comparable, averaging the observed outcomes reduces the amount of information available to be used in an analysis. ... The average gives equal weight to each observation being considered, while the use of the range minimizes the potential impact of any unknown or unquantifiable comparability defects. ...
Old website (cra-arc.gc.ca)

Taxable supplies - Special cases

Therefore, the amount of property taxes payable by a tenant is considered to be part of the rent and is subject to GST/HST in the same way as the amount of rent payable by the tenant. This will be the case whether or not the rental agreement states that the payment of property taxes by the tenant is to be considered as "rent" or "additional rent" However, if a tenant is directly liable to the municipality for the payment of property taxes, this amount is not subject to GST/HST. ...
Old website (cra-arc.gc.ca)

Information for Canadian Small Businesses : Chapter 2 – Setting up your business

A partnership is considered to be a person for GST/HST purposes. Therefore, it is important that you structure your affairs in a clear and understandable manner, since your reporting and remittance of GST/HST will depend on the type of structure you choose. ... The goodwill is considered to be an eligible capital expenditure, which is treated in a manner similar to assets eligible for CCA. ...
Old website (cra-arc.gc.ca)

Board of Management Oversight Framework - Administration of the Agency

Branch senior managers hold discussions with selected senior managers from functional and regional areas to ensure all critical risks are considered. ... Program coverage will be considered as a factor in developing future evaluation plans. ...
Old website (cra-arc.gc.ca)

Departmental Performance Reports - 2011-2012 Departmental Performance Reports - Section I: Organizational overview

As a result, Non-Respendable Non-Tax revenues are considered to be earned on behalf of the Government of Canada. ... During 2011-12, the CRA considered the environmental effects of initiatives subject to the Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals. ...

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