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In addition, the alternative provision includes a sentence dealing specifically with circumstances where services performed by an individual on behalf of one enterprise can be considered performed by another enterprise through that same individual and when they cannot. ...

Where the executor is a person who does not act in this capacity in the course of carrying on a business, the fee for acting as executor is considered to be income from an office. ...

(b) Clearly many costs incurred in respect of adjusting, or completing, income tax returns are not considered deductible by CRA or the courts. ...

That position was consistent with the view expressed by the CRA at the 2009 CTF Conference (reflected in Income Tax Technical News number 44) that unanimous shareholder agreements are not to be considered in applying paragraph (b) of the definition "Canadian-controlled private corporation" in subsection 125(7). ...

Would the impossibility of paying the full amount of the tax, combined with the fact that only one of the reassessments, at most, can be correct, give rise to a circumstance where a waiver of interest should be considered under the fairness provisions? ...

Raisons: In a situation where a trust cannot pay out the difference between its income for tax purposes and its income for accounting purposes, this difference is not considered as an amount payable pursuant to subsection 104(24). ...

In the circumstances you have described, it is the CRA’s view that the deposit balances of the non-resident pool participants would be considered “intermediary debts” for the purposes of subparagraphs 18(6)(c)(i) and 212(3.1)(c)(i), with the result that the back-to-back loan rules would be engaged, provided its other conditions are met. ...

3 May 2016 CALU Roundtable Q. 6, 2016-0633741C6- PHSP-sole employee dealing at arm's length CRA Tags 6(1)(a)(i) Principal Issues: Can a plan be considered a PHSP if an employer only has one employee who deals at arm's length with them? ...

If FA1 computes its earnings from its active business pursuant to subparagraph (a)(i) or (a)(ii) of the definition of “earnings” in subsection 5907(1) of the Income Tax Regulations (the “Regulations”) in accordance with the income tax law of the country in which it is resident or carries on the business and the interest paid to FA3 is deductible pursuant to the relevant country’s income tax law in computing such earnings, it will be considered to be deductible in computing the amount prescribed to be FA1’s earnings. ...

In this context, in order to determine the application of subsection 15(1), subsection 246(1), section 9 or paragraph 12(1)(x) of the Act, each arrangement must be considered based on its own facts, on a case-by-case basis. ...