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P-084R "Forgiven Debts Considered Bad Debts" 8 March 1999-- summary under Subsection 231(1) Summary Under Tax Topics- Excise Tax Act- Section 231- Subsection 231(1) [F]orgiven debts pursuant to an arrangement under the Companies' Creditors Arrangement Act are considered to be bad debts as opposed to reductions of consideration. ...

P-084R "Forgiven Debts Considered Bad Debts" 8 March 1999-- summary under Subsection 232(2) Summary Under Tax Topics- Excise Tax Act- Section 232- Subsection 232(2) [F]orgiven debts pursuant to an arrangement under the Companies' Creditors Arrangement Act are considered to be bad debts as opposed to reductions of consideration. ...

Certificate of residency "CRA cannot certify the residency of a partnership because partnerships are not considered resident; however, the individual partners of a partnership can ask for a certificate. ...

Underused Housing Tax Notice UHTN15, Questions and Answers About the Underused Housing Tax, 17 April 2023-- summary under Owner Summary Under Tax Topics- Other Legislation/Constitution- Federal- Underused Housing Tax Act- Section 2- Owner Meaning of “could reasonably be considered to be an owner” (para. 1.14) The reference to “could reasonably be considered to be an owner” does not include the beneficiaries of a trust. ...

In such cases, relief of arrears interest and any penalties payable may be requested and considered in accordance with the taxpayer relief provisions as described in IC 07-1R1.... 14. ... Factors considered re availability only of LImited Program 20. In general terms, the Limited Program provides limited relief for applications that disclose non-compliance where there is an element of intentional conduct on the part of the taxpayer or a closely related party. ... Generally, applications by corporations with gross revenue in excess of $250 million in at least two of their last five taxation years, and any related entities, will be considered under the Limited Program. 22. ...

When is the construction of a residential complex considered to begin? Generally, the construction of a residential complex is considered to begin at the time that excavation work relating to the residential complex begins. ...

Days if presence in Canada due to COVID-19 Travel restrictions might not count towards being considered to carry on business in Canada If a non-resident which is not resident in a treaty country can demonstrate that it has crossed the threshold of carrying on business in Canada only because of the Travel Restrictions, CRA “will consider whether administrative relief is appropriate on a case-by-case basis.” ...

Of the contractor's services, 60% are considered to be improvements to capital property and are included in determining the adjusted cost base of the property under the ITA. ...

CRA responded: A corporation would be considered to be a trust and loan corporation or a loan corporation for GST/HST purposes if it is considered as such a corporation under the federal Trust and Loan Companies Act or an equivalent provincial statute…[and] also [may] be [so] considered… if it is treated as such under other federal statutes. …In addition…a corporation whose principal business is the lending of money or the making of loans is a loan corporation. … Where a third party purchases or receives an assignment of a conditional sales contract, the third party would generally not be considered to be lending money or making a loan to the assignor of the conditional sales contract. In addition, where a person that is a mortgagee assigns a loan to a third party that the mortgagee has made to a mortgagor, the third party would not be considered to be making a loan to the mortgagor. ...

An employee on maternity leave will not be considered to be on leave with pay for purposes of the wage subsidy (see Q20-03). ... However, wages in lieu of termination notice are not considered to have been paid in respect of a week, and therefore are not eligible for the wage subsidy. ... For example, salaries and wages paid to a status Indian whose income is exempt from tax under a specific provision of the Act are considered eligible remuneration and would qualify for the purpose of calculating the wage subsidy. ...