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The relevant address of the recipient also does not have to be an address obtained in respect of every supply made to the recipient for it to be considered a relevant address obtained in the ordinary course of business. ...

Where a person receives a salary or other remuneration that is not based on its interest in the partnership, then that person is not considered to be acting in partnership with the other parties engaged in the subject activity [per contra, Zahid Solicitors]. ...

If you are not registered for the GST/HST, you are considered to be a monthly filer. ...

28 May 2025 IFA Roundtable, Q.3-- summary under Subsection 15(2.17) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.17) illustration of ordering rule for determining whether s. 15(2.17) applies to a cross-border notional cash pooling arrangement CRA indicated that anticipated frequent and ongoing movements in the account balances of participants to a notional cash-pooling arrangement would likely be considered to form part of a series of loans, repayments, and other transactions for s. 15(2.6) purposes. ...

Discussion of Category 3 The ordinary meaning of the term “established” when considered in the context of the words “other body established by a government” in the Act includes more than a body that is created by a government. ... Where the government has been involved in the setting up of the body for a specific purpose such that its actions indicate a clear intention to set up a “new body” that did not exist in that capacity before, that body might be considered “established” by a government. ...

In determining if an intermediary’s service is included in paragraph (l), all the facts surrounding the transaction, including the following factors, must be considered: the degree of direct involvement and effort of the person in the provision of a financial service referred to in any of paragraphs (a) to (i); the time expended by the intermediary in the provision of a financial service referred to in any of paragraphs (a) to (i); the degree of reliance of either or both the supplier and the recipient on the intermediary in the course of providing a financial service referred to in any of paragraphs (a) to (i); the intention of the intermediary to effect a supply of a financial service referred to in any of paragraphs (a) to (i); and the normal activities of an intermediary in a given industry (including whether the intermediary is engaged in a business of providing financial services). ...

") Example dealing with subheading 2.2.1 (Determine the extent of eligible work- "Support work"): Example 8 only the portion of project commensurate with SR&ED needs qualifies as such ("the company determined that 500 sticks [compared to a larger order of 2,000 field-hockey sticks] from the cutting and rasping machine would generate sufficient out-of-tolerance sticks to test and validate, with 95% confidence, that the development could be considered complete... ...

. … The amount in the reinsurance premium described above as the margin for risk transfer is not considered to be included in loading as defined in section 217. ...

Where the taxpayer concurs, and it is considered reasonable in the circumstances, CRA officials may utilize this guidance for taxation years prior to 2018. ...

As the Minister has the authority to accept these elections late, each request will be considered on a case-by-case basis. ...