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In the case where the Trust is not able to pay the balance of $25,000 of taxable income in the course of the year, we are of the view that this balance will not be considered to be payable by virtue of subsection 104(24). 9 October 2015 APFF Financial Strategies and Instruments Roundtable Q. 6, 2015-0595851C6 F Q.7 Processing delays for charity registrations (a) Is there a different registration process for a charitable organization and a foundation? ... The definition of “eligible offset amount” in subsection 108(1) (the “Definition”) encompasses the portion of any debt or obligation which is assumed by the taxpayer in respect of all or part of the taxpayer’s capital interest in a trust, and that can reasonably be considered to be applicable to property distributed in satisfaction of the interest, if the distribution is conditional upon the assumption by the taxpayer of the portion of the debt or obligation. ...

We are returning to the concept of the VDP as an application – not a submission that will merely be processed by a processing centre as submitted, but something that will get a bit of analysis upfront that will be considered on its facts. ... While CRA will engage in preliminary discussions on a no-name basis, the taxpayer is not considered protected until their identity is revealed. ... Was that a practice that the CRA considered in the policies? Response Ted Gallivan: This is an oversimplification, but I think the government of Quebec still looks at voluntary disclosures as a revenue-leader whereas we are looking at the VDP as a behaviour-influencer. ...

The review also considered the effectiveness of the pre-rulings consultation service, which has been in place since 2013. ... Most countries we considered have a system, similar to ours, that is discretionary and administrative. ... There is currently no link between that stated requirement, and whether the same or substantially similar transactions are being considered by a tax services office or for transactions under audit. ...

We've changed that practice in the past year or so, where, if you have an objection, and you want to have relief considered at the same time as your objection, the appeals officer has the duty to consider the interest or penalty relief at the same time that they are considering the objection, or the litigation for that matter. ... The appeals officer can give you a decision letter but we won’t reassess on the relief until the whole matter of the objection is considered and resolved. ...

The reason for the difference between the two types of reservations was that it was impossible to get the unanimous agreement of everybody in the room on all of the different free form reservations that were being considered by countries. ... This is generally considered more relevant to independent opinion-style arbitration than to baseball-style. ...

Based on the general definitions above, residential condominiums being real estate (immovable property in Québec), they would not be considered “goods” under paragraph 95(3)(b). ... The courts have repeatedly considered evidence beyond the location of board meetings in order to look at the whole “course of business and trading” of a corporation. ... [FN2: Decision rendered on November 26, 2021; [2021 SCC 49]] The SCC considered a matter central to the CRA’s ongoing efforts to protect Canada’s tax base and the integrity of its tax treaties. ...

Generally, for a right to receive an amount to be considered a right or thing of an individual within the meaning of subsection 70(2), the individual must be legally entitled to it at the time of death and the value of the right must be determinable at that time. ... (b) An immovable is normally considered to be a single property unless it is legally subdivided into two or more separate properties. ... As part of the Financial Strategies and Instruments Roundtable at the 2022 APFF Conference, a question was asked as to when an HBP repayment could be considered to reset the HBP balance to nil. ...

Finally, note that in the presence of a taxable inter-corporation dividend (actual or deemed), the potential application of subsection 55(2) should be considered, depending on the facts and circumstances of a particular situation. ... Although in certain circumstances the dividend paid by Opco to the holding corporation of the active shareholder may not be considered to have any of the purposes described in paragraph 55(2.1)(b), that determination can only be made after a review of all the facts of a particular situation. ... The portion of the dividend exceeds income earned or realized by a corporation that could reasonably be considered to contribute to the unrealized capital gain on Class B shares of the capital stock of the operating corporation held by the holding corporation ("safe income on hand"). ...

CRA Response to Q.8(a) and (b) Where an estate, considered to be a trust for purposes of the Income Tax Act, receives an amount as a superannuation or pension benefit, it must include that amount in computing its income pursuant to subparagraph 56(1)(a)(i) I.T.A. ... CRA Response to Q.9(b) To reflect the above response, an update to the Non-Resident Tax Calculator will be considered. ... Thus, holding RRSPs and RRIFs in trust will not change the fact that income from those plans will be considered "pension" income for purposes of the Convention. ...

Where, based on risk assessment and the regional work plans, we find that a TSO has more high-risk cases than they can complete based on their current work in progress, based on their resources, based on their technical capacity, and perhaps based on their industry knowledge, those additional cases that are identified will then be considered for workload portability. ... Where the risk is considered low, we'll try and close those files, and what remains would be high-risk, old outstanding years. ... If there are recurring issues, if the taxpayer is considered high risk, if the taxpayer has been less than transparent and cooperative with the CRA, then we will consider going back into earlier years to address those high-risk issues. ...