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It is our view that where the determination of an eligible entity’s wage subsidy claim for a CEWS benefit, computed using all of its eligible employees and eligible remuneration (and other required criteria specified in section 125.7), can be reconciled with each wage subsidy application, the NOD issued for each RP account should be considered to be valid under subsection 152(8). 4. ... As noted in technical interpretation 2014-0547641E5, this legislation supports the interpretation that any form authorized by the Minister is considered a prescribed form. ... Therefore, it is our view that where the determination of an eligible entity’s wage subsidy claim for a CEWS benefit, computed using all of its eligible employees and eligible remuneration (and other required criteria specified in section 125.7), can be reconciled with each wage subsidy application, the NOD issued for each RP account should be considered to be valid. 4. ...

Out of the amount of the AMT of $487, $66 (i.e. $487 x $25,000/$185,000) is reasonably considered to be attributable to U.S. source income which has been resourced to Canada. ... In such a case it could not be argued that regular U.S. tax on U.S. source income resourced to Canada should not be considered a voluntary tax because of the AMT. ... By allowing the MTC claim to be considered to come out of the portion of the AMT attributable to Canadian source income first, the Cdn. ...

Even if such amounts can be considered to have been "incurred" for purposes of paragraph 18(1)(a), it is our view that subparagraph 18(9)(a)(ii) would apply to deny the deduction of the excess amounts by the T/P as they represent an expense that can reasonably be regarded as having been incurred as or on account of rent in respect of a period after the end of the year. ...

March 2, 2012 Eli Moad Income Tax Rulings Directorate Charities Directorate Andrea Boyle, CGA Canada Revenue Agency 320 Queen Street 7th Floor Ottawa, ON K1A 0L5 2011-042281 Capacity in Which Director Loans Received I am replying to your email dated September 29, 2011 in which you asked for our views on whether amount received by a director would be considered to be received in his capacity as an employee in the circumstances described below. ...

In other words, a Site or Project must first meet all of the requirements of the Basic Rule and then it must be established that the Site or Project existed for a period exceeding 12 months as required under the Construction Paragraph before a Site or Project can be considered to be a PE. ...

The above position is different from the interpretation of the preamble of subsection 20(1) of the Act as set out in documents numbered 2008-0272441I7, 2003-0021817, 2002-015144, 2002-0151485, 2002-0150835, 9704727, 9615787, 9109706, and 9014576 and should be considered to override such earlier interpretations. ...

Section 41 of the TA generally speaking states that if on or before the filing-due date for a taxation year of a corporation, the corporation has received, is entitled to receive or can reasonably be expected to receive an amount that is government assistance, non-government assistance or a contract payment that can reasonably be considered to be in respect of SR&ED, the corporation should reduce the otherwise eligible expenditures incurred in the year in respect of SR&ED by that amount. ...

If the Liability is in fact separate and distinct from the shares of the FA as was concluded in the opinion, the subsequent payment of the Liability would not be considered a transaction "in respect of shares of the capital stock" of the FA for purposes of subsection 39(2). ...

.” In the instant case, the T1 Adjustment Request is considered to be the taxpayer’s return. ...

Responses Provided: Buying and Selling Goods or Services in Exchange for Bitcoins Income Tax Implications Virtual currencies, such as Bitcoins, are not considered to be a currency issued by a government of a country, such as American dollars. ...