Search - considered

There are a number of situations in which a charity might be considered to have a political purpose. ... In such a case, the purpose would very likely be considered a political purpose. ... The organization would therefore likely be considered to have a political purpose, and could not be registered as a charity. ...

. ¶1.31 has been modified for clarity by replacing the words “sets out the deemed dispositions which are not considered” with the words “provides that certain dispositions and acquisitions of property that are either deemed to be made by certain provisions of the Act or made in the course of certain rollover transactions are not dispositions or acquisitions”. ¶1.39 has been modified to improve readability by adding the words “paid by the partnership” immediately after the words “of the total foreign taxes” in the third sentence. ¶1.39.1 has been added to take into account the rules regarding artificial foreign tax credits generators under subsections 126(4.11) to (4.13) as enacted by S.C. 2013, c. 34 (formerly Bill C-48), s. 267(4). ... The reference to resource royalties was removed from the discussion of taxes in general since they may be a payment for a specific right or privilege, or may be part of a regulatory scheme and moved to the discussion of examples of what will not be considered an income or profits tax, to address the situation where they may be structured as a tax. ¶1.6 (formerly included in ¶5 of IT-270R3) now includes an additional bullet to reflect the operation of subsection 126(4). ¶1.7 (formerly included in ¶5 of IT-270R3) has been revised to reflect the primacy of Canadian law for characterizing a transaction, and calculating the income for the purposes granting a foreign tax credit in accordance with the language of section 126. ¶1.9 (formerly included in ¶5 of IT-270R3) now includes a reference to documentary or stamp taxes in the examples of items not considered to be income or profits taxes in consideration of the CRA’s position on the general nature of these taxes. ¶1.10 (formerly included in ¶5 of IT-270R3) has been revised to change business income to net business income in the first sentence for greater clarity. ¶1.16 (formerly included in ¶7 of IT-270R3) now includes an example describing a taxpayer with different taxing and business countries. ¶1.25 (formerly included in ¶8 of IT-270R3) has been reworded to remove ambiguity as to whether foreign was meant to describe the other person or partnership and to better reflect paragraph (e) of the definition of non-business-income tax in subsection 126(7). ¶1.26 (formerly included in ¶8 of IT-270R3) now includes a reference to the amendments to the overseas employment tax credit contained in the Jobs and Growth Act, 2012; edited to remove redundancy. ¶1.29- 1.31 are new additions which replace and expand on the parenthetical comment in ¶8 of IT-270R3, which read: (subject to subsections 126(4.1) and (4.2), which concern the no economic profit and short-term security acquisitions rules, respectively) ¶1.32- 1.35 (formerly included in ¶11 of IT-270R3) has been revised to omit the last sentence of former ¶11 and to add a discussion on what is meant by paid by the taxpayer for the year. ¶1.39 replaces and expands on the partnership information contained within parenthesis at ¶1- 2 of IT-270R3. ¶1.41 (formerly included in ¶15 of IT-270R3) has been revised to de-emphasize the word spouse and place greater emphasis on the filing of a valid, foreign, communal return. ¶1.42 (formerly included in ¶16 of IT-270R3) has been expanded to reflect amendments to section 261 and the CRA’s position regarding consistency in exchange rate methodologies. ¶1.46 (formerly included in ¶20 of IT-270R3) has been revised to clarify the situation of income arising from property which pertains to or is incidental to a foreign business. ¶1.49 (formerly included in ¶21 of IT-270R3) now references the Canada-UK Income Tax Convention. ¶1.51 (formerly included in ¶22 of IT-270R3) now contains a sentence to address subsection 91(5). ¶1.52 is a new paragraph added to point out that where a treaty is applicable; the treaty may have its own income sourcing rules which supersede those of the Act, but only for the purposes of eliminating double taxation in accordance with the treaty. ¶1.53 (formerly included in ¶23 of IT-270R3) now includes the phrase or profit generating activities for greater clarity, as well as a bullet referencing transportation or shipping businesses. ¶1.54 is a new paragraph added to reflect the jurisprudence on additional factors and the weighting of various factors when determining the location of the source of the business income. ¶1.57 (formerly included in ¶25 of IT-270R3) has been revised to change place to physical place to remove ambiguity. ¶1.58 (formerly included in ¶26 of IT-270R3) contains new sentences that reflect additional factors concerning the situs of income and their weight, as judicially addressed. ¶1.62 (formerly included in ¶3 of IT-395R2) has been revised to add and title was transferred to the second sentence and to add the third sentence for greater clarity. ¶1.63 (formerly included in ¶3 of IT-395R2) has been revised to add the phrase under the Act to remove ambiguity and to differentiate between foreign deemed dispositions and deemed dispositions under domestic law. ¶1.65 (formerly included in ¶4 of IT-395R2) now includes examples and a discussion of the relative weighting of various factors for consideration. ¶1.69 is a new paragraph added to address TFSAs and RRSPs. ¶1.70- 1.72 (formerly included in ¶37 of IT-270R3) has been revised to reflect legislative changes effective for the 2005 and later tax years, to make reference to the additional definitions involved, and to reference Guide 5000-G, General Income Tax and Benefit Guide. ¶1.73 (formerly included in ¶40 of IT-270R3) has been revised to change the treaty in the example to the Canada-India Treaty. ¶1.76 (formerly included in ¶2 of IT-270R3) has been revised to match the marginal note of subsection 120(1). ¶1.79 (formerly included in ¶3 of IT-270R3) has been expanded to better explain the operation of section 114 and subparagraphs 126(1)(b)(ii) and 126(2.1)(a)(ii). ¶1.80 (formerly included in ¶30 of IT-270R3) now includes the phrase not under the laws of the foreign jurisdiction in the first paragraph for greater clarity. ...

A stop between two legs of a journey that is 24 hours or less is not considered to be a stopover. However, a stop of more than 24 hours between two legs of a journey will generally be considered a stopover where two or more tickets or vouchers are issued for the legs of the journey. ... Therefore, each ticket has to be considered separately to determine whether GST or HST applies. ...

When completing the T3 return, follow the instructions in the T3 guide, and make sure that you: (a) complete all of the identification area on page 1; (b) identify the trust as a communal organization; (c) do not deduct any amount for salaries, wages, or benefits of any kind paid to any members of the congregation when calculating the trust's taxable income; (d) if you make an election regarding taxable income, determine the trust's modified taxable income; (e) if you make an election regarding donations and gifts, enter on Schedule 9, Summary of Income Allocations and Designations to Beneficiaries, the total amount of charitable donations and Crown and cultural gifts designated to members of the congregation; and (f) if the trust is allocating business, farming, or fishing income, enter on Schedule 9, in the area called "self-employment earnings," the total amount of business, farming, and fishing income allocated, since it is considered to be self-employment income for CPP contributions. 20. ... The income the trust allocates will be considered to be the income of the beneficiaries for the year from a trust. ... However, business income allocated by the trust is considered to be self-employment earnings for Canada Pension Plan contributions. 24. ...

Persons will be considered by the CRA to have exercised due diligence where it can be clearly demonstrated that they have to the best of their ability taken reasonable care in ensuring that the correct amount was remitted or paid when required, and/or that the return was filed by its due date. ... Decision Based on these facts, the registrant is not considered to have exercised due diligence in ensuring that the correct amount of net tax was remitted when required. ... The representative advises that the bar is not taxable since it is considered to be a “meal replacement” rather than “candy”. ...

Thus as stated above, because there in Québec is a possibility that the previous owner will redeem the property within a prescribed time period following the auction sale and because of the effect of the redemption, the issue is whether in that province the auction sale can be considered a supply for GST purposes. ... B is considered to be selling the land back to Mr. A for $ 53,500 plus interest. ... B is considered to be selling the land back to Co. A for $ 100,000 plus interest. ...

" In effect, activities or undertakings included in the definition of "business" in subsection 123(1) would also be considered activities or undertakings in the course of a "business venture. ... The company now has Canadian clients, but all business is conducted in the USA and Kruks Inc. is not considered to be doing business in Canada. 3 Kruks Inc. will incorporate this business in Canada (separate from its own corporation) before the actual commencement of business operations. 4. ... Even if the Consortium purchased real property in Canada, it is the Consortium's view that it would not be considered resident under subsection 132(2) of the Act since no supply will be made through the property at that point in time. ...

Even if you keep these amounts with your personal or business funds, the amounts are considered to be held separate and apart. ... Before starting legal action, the CRA must do the following: make 3 attempts to give verbal legal warning by phone send 1 written legal warning letter The notice of assessment or reassessment is considered the written legal warning for goods and services tax/harmonized sales tax (GST/HST) and payroll deduction amounts owing. ... Deemed trust claim letter The CRA has the authority to collect amounts considered held “in trust” by your business. ...

A couple who obtained a legal separation through Family Court is still considered married or common-law if they continue to reside in the same residence, and should report as such on their tax return until they no longer live together for at least 90 consecutive days. In other words, they would be considered married or living common-law until they no longer live together for at least 90 consecutive days. ... Note An individual is still considered to have a spouse or common-law partner if they were separated involuntarily. ...

Because Sven and Olga are adult siblings, they are considered 2 separate families. ... Category Kitchen Yes Renovating rooms or sections of the property Bathroom Yes Renovating rooms or sections of the property Basement Yes Renovating rooms or sections of the property Renovations to a cottage or cabin that is not your principal residence No Renovating rooms or sections of the property Carpet Yes New flooring Linoleum Yes New flooring Hardwood Yes New flooring Floating laminate Yes New flooring New furnace Yes Major appliances Boiler Yes Major appliances Woodstove Yes Major appliances Fireplace Yes Major appliances Oil tank Yes Major appliances Water softener Yes Major appliances Water heater Yes Major appliances Permanent home ventilation systems Yes Major appliances Central air conditioner Yes Major appliances Permanent reverse osmosis systems Yes Major appliances Electronic devices that are installed as a fixture Yes Major appliances Sofas, couches No Furniture and household appliances Beds No Furniture and household appliances Refrigerator or fridge No Furniture and household appliances Freezer No Furniture and household appliances Washer and dryer No Furniture and household appliances Range, stove, oven No Furniture and household appliances TVs, computers, tablets, smart devices, speakers, streaming devices, cellphones, gaming systems, and other audiovisual electronics No Furniture and household appliances Septic systems Yes Exterior Wells Yes Exterior Exterior shutters and awnings Yes Exterior Re-shingling a roof Yes Exterior Windows and doors Yes Exterior Underground sprinklers Yes Exterior Building an addition Yes Exterior Garage Yes Exterior Deck Yes Exterior Storage shed Yes Exterior Gazebo Yes Exterior Fence Yes Exterior A new driveway or resurfacing a driveway Yes Exterior Electrical wiring in the home (changing from 100 amp to 200 amp service) Yes Upgrades Home security system (monthly fees do not qualify) Yes Upgrades Solar panels and solar panel trackers Yes Upgrades Painting the exterior or interior of a housing unit Yes Upgrades Asbestos removal from house or garage Yes Upgrades Standby generators Yes Upgrades Automatic garage door openers Yes Upgrades Permanently fixed electric vehicle charging units Yes Upgrades Fixtures – blinds, shades, shutters, lights, ceiling fans Yes Upgrades Mechanical items not considered an enduring addition to the home No Upgrades In ground swimming pools Yes Swimming pools Above ground Yes Swimming pools Pool liners Yes Swimming pools Solar heaters and heat pumps for pools (does not include solar blankets) Yes Swimming pools Solar blankets for pools No Swimming pools Hot tubs No Swimming pools New sod Yes Upgrades Garden Yes Upgrades Perennial shrubs Yes Upgrades Flowers Yes Upgrades Trees Yes Upgrades Tree and stump removal Yes Upgrades Large rocks Yes Upgrades Crushed rock Yes Upgrades Permanent garden lighting Yes Upgrades Permanent water fountain Yes Upgrades Permanent ponds Yes Upgrades Large permanent garden ornaments Yes Upgrades Retaining wall Yes Upgrades Installation Yes Services and other costs Permits Yes Services and other costs Professional services Yes Services and other costs Equipment rentals Yes Services and other costs GST/HST paid Yes Services and other costs Incidental expenses Yes Services and other costs House cleaning No Services and other costs Carpet cleaning No Services and other costs Tools No Services and other costs Maintenance contracts (for example, furnace cleaning, snow removal, lawn care, and pool cleaning) No Services and other costs Financing costs No Services and other costs The value of your own labour for do-it-yourself projects No Services and other costs Amounts paid as part of the purchase of a new house, including upgrades No Services and other costs Expenses to acquire goods that have been previously used or leased by you or an eligible family member No Services and other costs Window coverings To qualify for the credit, window coverings must have become part of the home. ... They would then be considered to be fixtures, and so qualify for the Home Renovation Tax Credit. ...