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Where the election is not included with the return of income filed, the election would be considered late. ... Is the trust considered not to deal at arm’s length with Parent such that paragraph 43. 1(2)(b) will apply? ... If an individual is not considered a factual resident of Canada based on residential ties, they may still be considered a deemed resident under subsection 250(1). ...

The economic substance test first reverses what some would regard as the existing default approach towards dealing with economic substance, arising from Canada Trustco, where a lack of economic substance is generally considered to be irrelevant, unless the provisions otherwise indicate that the transaction is inappropriate. ... This also raises the question of when Jane is considered to be “in the group.” ... I do appreciate that that came in at 25% and went up to 50% and then added on a prohibition on government contracts for those considered subject to the GAAR or not reported, but we did 25%. ...

In such a scenario, could part of the services rendered by USco be: A. considered “services rendered in Canada” for purposes of Regulation 105; and B. considered “services… provided in that other State" for purposes of Article V:9(b) of the Canada-U.S. ... CRA document 2018-0776661I7 indicates that a miner who receives a bitcoin for validating transactions will be considered as having rendered a service. ... T1134 Missing Substantial Information (for 2021 and later taxation years) In technical interpretation 2019-0791541I7 the CRA indicated that an information return missing substantial information will be considered invalid, and therefore, will not be considered to have been filed. ...

Furthermore, pursuant to the Technical Explanation to the 2007 Protocol to the Treaty, where Article IV(6) applies to deem a U.S. resident to be considered to derive a Canadian-source dividend, such dividend is considered as being paid to that U.S. resident. As such, dividends paid by the ULC in the example provided above would be considered as being paid to USCo1 and USCo2. ... The above comments should be considered whenever there is a conversion, from a Canadian tax perspective, from a partnership to a corporation. ...

., from the time of the sale forward, the contribution is considered to have never occurred). ... Accordingly, the other factors used to determine if the specified individual is actively engaged in the activities of the business must be considered. ... That being said, there are certain questions of fact and law that must be considered. ...

Q7: Deemed Resident Trust and CCPC Status A trust which meets the conditions of section 94 is considered resident for certain purposes of the Act. ... Since subsection 94(3) does not state that a deemed resident trust is considered resident for purposes of determining control, we would imagine that the corporation would not be considered Canadian controlled. ... Q15: Trust and Estates Issues Can the CRA provide an update on some of the recent issues that it has considered relating to trusts and estates? ...

Thus, an agreement that is not an unanimous shareholder agreement would not generally be considered in determining de jure control of the corporation. ... It is considered to be one of the hallmarks indicative of a genuine intergenerational business transfer. ... The result is that the termination of the Bare Trust would not be considered to result in a disposition of the property held by the Bare Trust. ...

As an example, a U.S. limited liability limited partnership or U.S. limited liability company is considered to be a corporation for Canadian tax purposes but is considered as fiscally transparent or as a partnership by default under U.S. tax law. ... US LP is considered a flow-through entity for U.S. income tax purposes, but is not disregarded. ... LLC is not considered to be a resident of the U.S. for purposes of the Treaty. ...

Although the committee considered that the transaction circumvented the integration principle, it recommended that the GAAR not be applied. ... Why we changed our position is that we did not want plans to be considered offside on the basis of nominal or incidental non-METC coverage. ... Assume that FA #2 acquires a 95% interest in Target such that Target is considered to be a partnership for US tax purposes. ...

In Québec, it has been determined that a call option is considered to be IPP that relates to real property. ... X, it does not appear that such free supplies would be considered to further the making of taxable supplies for consideration. ... As a result, it is unclear why the application of subsection 141.01(2) of the ETA would need to be considered. ...