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For example, a business that was considered to be operating primarily to provide instruction in languages in a fiscal year and that intends to continue to operate in the same manner would be considered to be operated primarily to provide instruction in languages in the following fiscal year. However, if the portion of the business’s total annual revenues that is derived from language course fees/tuition or that can be attributed to instruction in these courses falls to 50% or less during the following fiscal year, the business would no longer be considered to be operated primarily to provide instruction in languages in the next fiscal year. ...

An entity must meet all of the conditions set out in this definition to be considered a non-profit organization for the purposes of the Act. ... A non-profit organization is considered to have been "established primarily for the benefit of organized labour" if it was established primarily to provide some advantage to organized labour, such as: a trade union as defined in section 3 of the Canada Labour Code; a trade union as defined in any provincial act that provides for the investigation, conciliation, or settlement of industrial disputes; an association of public servants whose primary object is to promote the improvement of the members’ conditions of employment or work; or a parity or advisory committee or similar body. 15. ... Therefore, Organization A is considered to have been "established primarily for the benefit of organized labour". ...

A financial institution (FI) would generally be considered to be an SLFI throughout a reporting period in a fiscal year that ends in a particular taxation year of the FI if it is an LFI described in any subparagraphs 149(1)(a)(i) to (x) at any time during the particular taxation year, and the FI has a permanent establishment in a participating province and a permanent establishment in any other province, at any time during the taxation year. ... Insurance companies and fraternal benefit societies that are registered federally or provincially are generally considered to be LFIs. ... Person whose principal business is the lending of money or the purchasing of debit securities or a combination thereof – A person that carries on business principally as a finance company, acceptance company, factor, venture capitalist, or a loan, mortgage or investment company is considered to be an LFI. ...

Conclusion: The enhancements relating to the new accounts created for PEI were considered to be appropriate and mapped to the correct RL accounts. ... Based on our sample review of the applicable changes, the enhancements relating to the new accounts created for PEI were considered to be appropriate. ... Conclusion The enhancements relating to the new accounts created for PEI were considered to be appropriate and mapped to the correct RL accounts. ...

" The criteria to consider in determining the most appropriate method to the circumstances of the case are: "(…) the respective strengths and weaknesses of the OECD recognised methods; the appropriateness of the method considered in view of the nature of the controlled transaction, determined in particular through a functional analysis; the availability of reliable information (…) needed to apply the selected method and/or other methods; and the degree of comparability between controlled and uncontrolled transactions, including the reliability of comparability adjustments that may be needed to eliminate material differences between them. ... Although not compulsory, this "typical process" is considered good practice by the OECD. ... In addition, in order to correct a misquote of the Guidelines, the last sentence of this paragraph is revised to read "The OECD Guidelines identify two exceptional situations where disregarding a transaction would be considered." ...

Subsection 247(4) of the Act deems a taxpayer not to have made reasonable efforts to determine and use arm’s length transfer prices or allocations for purposes of the penalty provision in subsection 247(3) of the Act, for the taxation years (or fiscal periods) under review, unless the taxpayer complies with the following three requirements: The taxpayer makes or obtains, on or before the taxpayer’s documentation-due date (defined in subsection 247(1) of the Act) for the taxation year or fiscal period in which the transaction is entered into, records or documents that provide a description that is complete and accurate in all material respects of: the property or services to which the transaction relates; the terms and conditions of the transaction and their relationship, if any, to the terms and conditions of each other transaction entered into between the participants in the transaction; the identity of the participants in the transaction and their relationship to each other at the time the transaction was entered into; the functions performed, the property used or contributed and the risks assumed for the transaction by the participants in the transaction; the data and methods considered and the analysis performed to determine the transfer prices or the allocations of profits or losses or contributions to costs, as the case may be, for the transaction; and the assumptions, strategies and policies, if any, that influenced the determination of the transfer prices or the allocations of profits or losses or contribution to costs, as the case may be, in respect of the transaction. ... Documentation provided to the CRA under different circumstances or obligations (such as documentation provided with an APA submission or in a return) is not considered documentation previously provided to the CRA for the purposes of the current request for contemporaneous documentation. ... If these conditions are met and the documentation does exist, it will then be considered to have been provided within three months after the request for contemporaneous documentation was served. ...

Some of the courses listed above may require a combination of courses to be considered equivalent depending on the recognized postsecondary institution. ... However, if an acceptable specialization in accounting is required for a position, an employee who has acquired rights but does not have the acceptable accounting courses cannot be considered for the position. ... Candidates possessing a bachelor’s degree in engineering or computer science with an acceptable combination of education, training and/or experience will be considered as meeting the education standard. ...

If you make an “in-kind” contribution to your FHSA, you will be considered to have disposed of the property at its fair market value (FMV) at the time of the contribution. ... When the non-qualified investment ceases to be a non-qualified investment while it is held by the FHSA trust, the FHSA trust is considered to have disposed of the property at its FMV right before that time and to have re-acquired the property for the same amount at the same time. ... When the prohibited investment ceases to be a prohibited investment while it is held by the FHSA trust, the FHSA trust is considered to have disposed of the property at its FMV right before that time and to have re-acquired the property for the same amount at the same time. ...

An early payment discount to which section 161 applies is not considered to be a reduction of consideration. 10. A reduction in consideration is not considered to have occurred if the goods are sold back to the original supplier. To be considered a reduction of consideration, it must be evident that the goods are being returned to the supplier rather than being sold to the supplier. ...

Since April 30, 2023, falls on a Sunday, your return will be considered filed on time if the Canada Revenue Agency (CRA) receives it, or it is postmarked, on or before May 1, 2023. ... Your payment will be considered on time if the CRA receives it, or a Canadian financial institution processes it, on or before May 1, 2023. ... In addition, certain expenses incurred in Canada for a surrogate or donor may be considered medical expenses of the individual, if they are of a type that would be otherwise permitted as medical expenses of the individual. ...