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Current CRA website

Major classification variables

We used the following variables in one or more of the tables in this publication: taxable or non-taxable income classification major source of income age and sex province or territory of residence Taxable or non-taxable classification We considered a return taxable if there was at least $2 of tax payable. We considered a return non-taxable when the sum of federal tax and provincial tax was less than $2. ...
Current CRA website

Chapter History S4-F2-C1, Deductibility of Fines and Penalties

Generally, certain intangible property, which before 2017 was considered eligible capital property, is added to class 14.1 of Schedule II to the Regulations. ... Legislative and other changes ¶1.1 (formerly included in ¶1 of IT-104R3) has been expanded to note that the terms penalty and fine are not defined in the Act. ¶1.2 has been added to summarize the income tax provisions that should generally be considered in determining the deductibility of a fine or penalty. ¶1.3 has been added to note that the deductibility of a fine or penalty can only be determined after examining all relevant facts. ¶1.4 to 1.7 have been added to discuss section 67.6, which was added by S.C. 2005, c. 19, s. 16(1), applicable to fines and penalties imposed after March 22, 2004. ...
Current CRA website

Computer-generated official donation receipts

A computer-stored copy does not require a signature to be considered a duplicate. ... Therefore, the computer-stored receipt can be considered a duplicate for purposes of the Act. ...
Current CRA website

Sponsorship

If a business receives special recognition for its donation, or if it receives more than minimal recognition (for example, banners or advertising of products), this is considered sponsorship. ... However, the business may be able to include the sponsorship costs in its advertising expenses, but only if this sponsorship is considered reasonable and was given with the intent of generating income. ...
Current CRA website

Definitions for Tax shelters

Limited-recourse debt in respect of a gift or monetary contribution A limited-recourse debt in respect of a gift or monetary contribution made after February 18, 2003 includes all of the following: each limited-recourse amount that relates to the gift or monetary contribution that is incurred by a person (or any other person not dealing at arm's length with the person) each limited-recourse amount that relates to the gift or monetary contribution that is incurred by another person dealing at arm's length with a person but that directly or indirectly holds an interest in the person any other amount that is unpaid indebtedness of a person described in a) or b) that relates to the gift or monetary contribution, if there is a guarantee, security or other indemnity or covenant in respect of that or any related indebtedness A limited-recourse debt includes the unpaid principal of any indebtedness, that can reasonably be considered to relate to the gift or monetary contribution, for which recourse is limited, even if that limitation applies only in the future or contingently. It also includes any other indebtedness of the person that can reasonably be considered to relate to the gift or monetary contribution if there is a guarantee, security or similar indemnity or covenant in respect of that or any other indebtedness. ...
Current CRA website

Non-qualifying security

A non-qualifying security is considered to be an excepted gift if it meets all of the following criteria: it is in the form of a share the donee that receives the non-qualifying security is not a private foundation the donor deals at arm's length with the donee when the donee is a charitable organization or a public foundation, the donor deals at arm's length with each of the charity's directors, trustees, officers, and like officials Commentary When the non-qualifying security rules apply, the gift is considered to have been made at the time the property ceased to be a non-qualifying security, or when it is disposed of by the donee. ...
Current CRA website

Chapter History S5-F1-C1, Determining an Individual's Residence Status

It was considered that the new title, Détermination du statut de résidence d’un particulier is more precise and better reflects the Chapter contents. ¶1.6 has been revised to replace the word “individual” with the word “person” when describing subsection 250(3), in order to reflect the wording of the legislation. ¶1.24 has been revised to remove the references to Guide T4056, Emigrants and Income Tax and Pamphlet T4131, Canadian Residents Abroad. ... Legislative and other changes The Summary has been expanded to preliminarily introduce readers to the terms resident, ordinarily resident, deemed resident, non-resident, and deemed non-resident as well as to provide a brief outline of the respective individual’s liability for Canadian income tax. ¶1.5- 1.9 (formerly included in ¶2 – 3 of IT-221R3) have been expanded to include additional discussion of the meaning of the terms resident and ordinary resident based on the Supreme Court of Canada’s decision in Thomson v Minister of National Revenue, [1946] S.C.R. 209, 2 DTC 812. ¶1.24 has been added to provide reference to CRA pamphlets and guides relevant to individuals emigrating from, or temporarily living outside of, Canada. ¶1.29 has been added to provide reference to CRA pamphlets and guides relevant to individuals immigrating to Canada. ¶1.33 (formerly included in ¶21 of IT-221R3) has been expanded to provide additional guidance in distinguishing a commuter from a sojourner. ¶1.35 has been added to provide CRA’s interpretation of the phrase “immediately prior to appointment or employment” as contained in paragraph 250(1)(c). ¶1.39 has been added to provide reference to CRA guides relevant to non-residents and deemed non-residents of Canada. ¶1.41- 1.44 have been added to outline the meaning of the term liable to tax for purposes of determining whether an individual is considered resident in a country for purposes of paragraph 1 of the Residence article of a particular treaty between Canada and another country. ¶1.46- 1.50 (formerly included in ¶26 of IT-221R3) discuss the permanent home and centre of vital interests tests. ...
Current CRA website

TPM-11

Criteria for accepting an APA rollback The CRA will usually agree to consider a request to expand the period of an APA to cover transactions in open taxation years where: a request for contemporaneous documentation has not been issued by a tax services office (TSO) the facts and circumstances are the same the foreign tax administration and the relevant TSO have both agreed to accept the APA rollback request and appropriate waivers, in the form outlined in subparagraph 152(4)(a)(ii) of the Act, have been filed Effect of APA rollback on the transfer pricing penalty Once an APA is in force, the results for the covered transactions occurring within the period specified in the APA will be considered to have satisfied section 247 of the Act. ... A taxpayer is considered to have requested an APA rollback once a pre-filing meeting has taken place between the taxpayer and the Competent Authority Services Division (CASD) officials regarding a potential APA rollback. ...
Current CRA website

Offshore Compliance Advisory Committee – Terms of reference

It does not include recommendations for specific legislative proposals; however, it may include broadly framed recommendations on relevant areas of legislation to be considered by the CRA for review and perspectives on potential implications of legislative changes. ... To assist the committee, the CRA will propose the scope and suggested output for the subject being considered by the committee, e.g., discussion, report, recommendations, comparative analysis, etc. ...
Current CRA website

About free tax clinics

This may include: adults 65 years and older housing-insecure individuals Indigenous Peoples modest-income individuals newcomers persons with disabilities students and youth Modest Income The following table provides a guideline to determine what is considered a modest income. ... Any other type of foreign income (including a foreign pension) would not be considered a simple tax situation. ...

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