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. … While stand-alone industry safety courses may be beneficial, and in some cases a job requirement, on their own they would not be considered to lead to an occupation. ...

. … [I]f the portion of the business’s total annual revenues that is derived from language course fees/tuition or that can be attributed to instruction in these courses falls to 50% or less during the following fiscal year, the business would no longer be considered to be operated primarily to provide instruction in languages in the next fiscal year. ...

This deemed tax paid would be considered to be an eligible amount upon which the designated pension entity may claim a rebate. ...

Does CRA agree that where the “income method” is used to determine the FMV of a MURC, that the FMV thereby derived should be considered to be inclusive of GST/HST, so that such GST/HST should then be backed out for purposes of coming to a reduced corrected FMV for purposes of s. 191(3)? ...

Situations where a referral to Audit is discretionary include, but are not limited, to: Where the net tax was estimated due to insufficient books and records; Where the input tax credits were disallowed as the accounting records and/or documentation were not provided; Where the new information provided for review is substantial; Where an on-site visit is warranted to verify certain facts provided by the taxpayer; Where the objection relates to an initial assessment concerning issues of prior years' returns currently being considered by Audit. ...

Since NewCo thus is not considered to have constructed or substantially renovated the residential complex, it is not a “builder” under paras. ...

For this method to be considered fair and reasonable by the CRA, property and services that can be attributed using the direct allocation method must represent a significant part of the registrant's overall inputs. 53. ...

Given that customer is acquiring an improvement to their property in the form of the deck which is a tangible improvement affixed to the customer’s property, to the extent that the revenues reflect the provision of the materials, they are considered a non-service component provided together with, as opposed to incidental to, the services. ...

If your partnership has a corporation or a trust as a member, under the rules you should complete the following steps: Provide each member with detailed calculations of the partnership’s IFE and IFR Provide each member with detailed calculations of the RAIFE and RAIFR of any CFA of the partnership Notify each member in writing of their allocated share for the year of: IFE in Canadian exploration expenses, Canadian development expenses, Canadian oil and gas expenses, and foreign resource expenses The income or loss that can reasonably be considered to come from activities funded by a borrowing or other financing that results in exempt interest and financing expenses Filing approach before Schedule 130 is ready Schedule 130 … Schedule 130 information is still required even though the form is not available. … Corporations and trusts … When you report your foreign accrual property income, you must adjust for RAIFE denied under subclause 95(2)(f.11)(ii)(D)(I) and include amounts in respect of a CFA’s partnership under subclause 95(2)(f.11)(ii)(D)(II). ...

The relevant address of the recipient also does not have to be an address obtained in respect of every supply made to the recipient for it to be considered a relevant address obtained in the ordinary course of business. ...