Search - considered

The comfort letter provides an exception from the tracking interest rules if it cannot reasonably be considered that one of the purposes for the creation or issuance of a tracking interest in an umbrella corporation or for the acquisition of the interest by a taxpayer is to avoid the corporation being a CFA for the year. ...

A supply of real property under an emphyteutic lease is considered a supply of real property by way of lease, licence or similar arrangement for GST purposes. ...

These packages are all considered a single supply of promotional services, because, amongst other things, it is not possible for a sponsor to choose which benefit it wants and to only pay that price. ...

The kindergarten program is not considered to be part of the elementary school program in Province B. ...

The amount of the Canadian journalism labour tax credit for a taxation year is considered to be assistance received by a qualifying journalism organization from a government, immediately before the end of the year (other than for the purpose of determining the Canadian journalism labour tax credit itself), and must be included in the income of the qualifying journalism organization for that year, as set out in paragraph 12(1)(x) of the Act. ...

Activities that fall outside of these categories may not be related to journalism, and will be considered by the CRA on a case-by-case basis. ...

Because it has qualified for the first claim period, the eligible employer is automatically considered to have experienced the required reduction in revenue for the second claim period (April 12 to May 9, 2020). ...

For purposes of paragraph 20(1)(dd), it is immaterial whether the site is land owned by the taxpayer or land being considered for possible purchase by him. ...

When asked as to whether it considered this decision to be portable to the situation where a non-resident person with a branch in Canada wishes that branch to be treated as resident in Canada for purposes of the ETA s. 156 election (presumably to be made with a Canadian corporate affiliate), CRA responded that it was considering the decision’s “impact on section 132,” but that: Subsection 132(2) deems a non-resident person with a permanent establishment in Canada to be resident in Canada “in respect of, but only in respect of activities of the person carried on through that establishment”. ...

27 February 2020 CBA Roundtable, Q.22-- summary under University Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- University Fraser International (re a university not needing to grant degrees regarding a college that is to be affiliated for GST/HST) will be followed on materially similar facts Memorandum 20-3, para. 7 states: An organization is only considered to be operating a college affiliated with a university where there is a formal affiliation agreement that states that the parent organization (the university) agrees to grant degrees to graduates of the affiliated college in exchange for a certain amount of control over the academic standards of, and the courses offered by, the affiliated college. ...