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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. ...

Where a person receives a salary or other remuneration that is not based on its interest in the partnership, then that person is not considered to be acting in partnership with the other parties engaged in the subject activity [per contra, Zahid Solicitors]. ...

If you are not registered for the GST/HST, you are considered to be a monthly filer. ...

Regarding the requirement in s. 70(6) that the spousal trust be created by the taxpayer’s will, CRA noted that the spousal trust thus needed to be separate from the estate, and also noted that, per s. 248(9.1), the spousal trust would be considered to be created by the deceased’s will if it was created under the terms of the will. ...

Discussion of Category 3 The ordinary meaning of the term “established” when considered in the context of the words “other body established by a government” in the Act includes more than a body that is created by a government. ... Where the government has been involved in the setting up of the body for a specific purpose such that its actions indicate a clear intention to set up a “new body” that did not exist in that capacity before, that body might be considered “established” by a government. ...

In determining if an intermediary’s service is included in paragraph (l), all the facts surrounding the transaction, including the following factors, must be considered: the degree of direct involvement and effort of the person in the provision of a financial service referred to in any of paragraphs (a) to (i); the time expended by the intermediary in the provision of a financial service referred to in any of paragraphs (a) to (i); the degree of reliance of either or both the supplier and the recipient on the intermediary in the course of providing a financial service referred to in any of paragraphs (a) to (i); the intention of the intermediary to effect a supply of a financial service referred to in any of paragraphs (a) to (i); and the normal activities of an intermediary in a given industry (including whether the intermediary is engaged in a business of providing financial services). ...

") Example dealing with subheading 2.2.1 (Determine the extent of eligible work- "Support work"): Example 8 only the portion of project commensurate with SR&ED needs qualifies as such ("the company determined that 500 sticks [compared to a larger order of 2,000 field-hockey sticks] from the cutting and rasping machine would generate sufficient out-of-tolerance sticks to test and validate, with 95% confidence, that the development could be considered complete... ...

. … The amount in the reinsurance premium described above as the margin for risk transfer is not considered to be included in loading as defined in section 217. ...

Where the taxpayer concurs, and it is considered reasonable in the circumstances, CRA officials may utilize this guidance for taxation years prior to 2018. ...