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Current CRA website

Excise and GST/HST News - No. 90 (Fall 2013)

GST/HST issues Generally, fundraising by its very nature is considered a profit activity. Organizations that are established and operated for the sole purpose of raising funds are not considered non-profit organizations for GST/HST purposes, even if all the profit from a fundraising activity is donated to a registered charity. ... Income tax issues As previously mentioned, fundraising by its very nature is generally considered a profit activity. ...
Current CRA website

GST/HST and Commercial Ride-sharing Services

You will be considered to be making such supplies once you start providing commercial ride-sharing services, including commercial carpool services. ... However, if your combined total annual revenue from taxable supplies of commercial ride-sharing services and other taxable supplies exceeds $30,000 (for example, $20,000 for commercial ride-sharing services and $15,000 for other taxable supplies), you will not be considered a small supplier. ... If you are already registered for the GST/HST, including with respect to another commercial activity, you are automatically considered to be registered with respect to your commercial ride-sharing services and are not required to apply for registration again. ...
Current CRA website

Imported Computer Software

Software supplied on a carrier medium is considered to be a supply consisting of the physical carrier medium (e.g., the disk) and the software stored on the disk (e.g., the instructions). ... Tax Treatment of Licensed Custom Software Tax Treatment Under Division II Under subparagraph 142(1)(c)(i) of the Excise Tax Act, a supply of intangible personal property is considered to be made in Canada if the property may be used in whole or in part in Canada and: the recipient is a resident in Canada or registered for theGST; and the supplier, even if a non-resident, is registered for the GST. ... Other Imported Computer Software Arrangements Electronic transmission of software A supply of computer software that is transmitted electronically is considered to be a supply of intangible personal property. ...
Current CRA website

The GST/HST and the Purchase, Use and Sale of Vacation Properties by Individuals

For example, if, at the time of purchase, Dennis intends to use his vacation property for his personal use for 35 days of the year and to make the property available, through a rental pool, for rent on a taxable short-term basis for the remainder of the year, the property would not automatically be considered to be used all, or substantially all, for commercial activities. ... All of the relevant factors should be considered when determining the extent of use in commercial activities at the time an ITC is being claimed. ... As a registrant, Sally is considered to have collected and is required to account for the GST/HST in determining her net tax. ...
Current CRA website

Applying the 2010 Nova Scotia HST Rate Increase - Transportation Services and Passes

A person only has to accept responsibility as the supplier of the freight transportation service to be considered the carrier. ... 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. ...
Current CRA website

Courses that Qualify for Exemption Pursuant to Section 8 of Part III of Schedule V to the Excise Tax Act

The intention of the person enrolling in the course is not considered by the Department in determining whether a course relates to a trade or vocation. (3) Attest to the Competence of Individuals to Practice or Perform a Trade or Vocation Section 8 requires the certificate, diploma, licence or similar document issued by an educational institution to "attest to the competence of individuals" to practice a trade or vocation. ... (a) Courses That Are Part of a Full-time Program An individual course is considered by the Department to attest to the competence of individuals to practise or perform a trade or vocation if: (i) The course is offered as a credit in a full-time program that is offered by the same institution; and (ii) The full-time program is offered on a pass/fail basis, based on the evaluation of the student's performance on a single, or series of, tests, graded materials or projects. ... Factors considered by the Department in determining whether a program of courses represents a 'full-time' program include the length of the program, the cost of the program and the curriculum and description of the program and its courses, as noted in the school's promotional material (e.g., brochures, advertisements, literature, course calendars, syllabi and telephone listings). ...
Current CRA website

Draft GST/HST Policy Statement, Research Activities Undertaken by Hospital Authorities – Entitlement to Rebates and Tax Status of Services

Decision Research activities that are related to care provided to inpatients and outpatients of a public hospital are considered to be activities engaged in by a hospital authority in the course of operating a public hospital. ... Examples of research activities that are, and are not, considered to be related to patient care for purposes of the public service body rebate can be found under the heading "Research and activities of operating a public hospital". ... A facility that does not have all the above characteristics is not considered to be a public hospital for purposes of the definition of hospital authority and the entitlement to the 83% rebate of the GST and federal part of the HST and corresponding rebate of the provincial part of the HST for tax incurred in activities of operating a public hospital. ...
Current CRA website

Audit Agreement and Waiver of Objection Rights Guidelines

It does not prevent the Minister from assessing or auditing the taxpayer for other taxation years, and/or for other issues not considered under the audit agreement. ... The relevant International Advisory Services Section Manager of the International Tax Division must be consulted in all cases where an audit agreement is being considered for a transfer pricing issue. ... To help ensure that the taxpayer fully understands all the facts and the consequences related to both the audit agreement and the waiver, there must be a meeting with the taxpayer and any representative to discuss the following topics: rationale for the method to be used to assess each issue being resolved and the applicable ITA/ETA sections taxation years pertinent to each issue degree to which the taxpayer understands the rationale for the assessment of each issue being resolved taxpayer's rights of objection and appeal prior to waiving objection rights and the fact that objection and appeal rights will not be available after signing the waiver taxpayer's right to seek independent legal advice financial impact of waiving objection rights for each issue, without interest calculation; explanation that the agreement does not establish any general or administrative precedent applicable to any other taxpayers understanding that the agreement depends on the specific facts disclosed and that the CRA may consider the agreement invalid if significant and material new information comes to the attention of the CRA the audit agreement is considered binding upon the taxpayer and their legal representative (where applicable) provided the taxpayer: signs and returns the waiver document and it has been signed freely and without duress; fully disclosed all material facts in its returns (e.g., T1, T2, T3, etc.), elections and applications; and fully disclosed all material facts related to the issues dealt with in the audit agreement. ...
Current CRA website

Proposed Amendment Addressing Mining Activities in respect of Cryptoassets

Collection of tax Prior to February 5, 2022, where a person performs a mining activity of validating transactions and adding them to a publicly distributed ledger as a solo miner that is engaged in a commercial activity, the provision of those activities would be considered a taxable supply for GST/HST purposes. ... Each particular person within the pool or group is considered to perform these mining activities in a similar fashion as a solo miner. ... The requirements to self-assess tax under Divisions IV and IV.1, as set out previously for solo miners, may also need to be considered. ...
Current CRA website

Charitable work and ethnocultural groups – Information on registering as a charity

Examples of ethnocultural group activities that could qualify as the advancement of religion teaching a religion running a religious school establishing a mosque, church, temple, or other place of worship for religious uses repairing a place of worship (iv) Other purposes that benefit the community Generally, purposes that fit under the relief-of-poverty, the advancement-of-education, and the advancement-of-religion categories are considered to benefit the community even if they are focused on an ethnocultural group. ... For example, banquets, picnics, and Canada Day celebrations are not considered charitable purposes. ... A Canadian charity can only transfer sums of money or other resources to foreign charities that are considered qualified donees. ...

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