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Table of Contents Issue Meaning of significant terms Background Decision Discussion Example Facts Decision Rationale Issue This policy statement provides the Canada Revenue Agency’s (CRA) position concerning when an insurer is considered to be making an exempt supply of a financial service in relation to a new home warranty. ...

There is more land in this parcel than is considered reasonably necessary for the use or enjoyment of the residential complex as a place of residence for individuals. ...

The deck design is considered to be a service. Page details Date modified: 2019-07-10 ...

. ¶1.36 has been added to list factors summarized by the Federal Court of Appeal in Rich v the Queen 2003 FCA 38, 2003 DTC 5115 that are normally to be considered in establishing whether a debt has become a bad debt. ¶1.37 and 1.38 have been added to reflect the Federal Court of Appeal’s comments in Rich about the consideration to be given to other factors, namely, future prospects of the debtor and, any non-arm’s-length relationship between the creditor and the debtor. ¶1.44 has been added to describe subparagraph 40(2)(g)(ii). ¶1.45 has been added to clarify that for purposes of the exception in 40(2)(g)(ii), the income-earning-purpose requirement refers to that of the creditor who lends the funds to, or guarantees the debts of the corporation. ¶1.46 has been added to reflect the Federal Court of Appeal decision in Byram v The Queen, 1999 DTC 5117 (FCA); [1999] 2 CTC 149. ¶1.47 has been added to reflect that in terms of meeting the exception for income-earning purpose in subparagraph 40(2)(g)(ii), there must be sufficient connection between the creditor making the loan to, or guaranteeing the debts of the corporation, and the potential for earning income from business or property. ¶1.52 (formerly ¶8(b) of IT-484R2) has been updated to reflect that clauses 39(1)(c)(vi)(B) and (C) were amended by S.C. 2000, c.12, Sch. ...

The terms and conditions should stipulate that an arrangement is not considered a qualifying arrangement unless the holder is at least 18 years of age when the arrangement is entered into. ...

Member contributions towards an unfunded liability To speed up our review when plan members contribute towards an unfunded liability, please confirm that: member contributions are calculated based on the actuarial liabilities for service accrued before the contribution is required the contributions cannot reasonably be considered to be for the member’s own benefits the contributions are made under an arrangement approved by the Minister under which all or a significant number of the active members of the plan must make similar contributions the main purpose for the arrangement is to make sure that the plan is adequately funded Conditional waiver In limited circumstances, we may grant your waiver request on a conditional basis if you have not sent us the relevant amendment. ...

Tips and gratuities: Tips and gratuities that are controlled by you and received from the performance of services are considered income from employment. ...

For further clarity, signature images and clipart are not considered secure electronic signatures. ...

The CCRA has the authority to specify the activities that may be carried out under a licence and the premises where these activities may be carried out, as well as to impose any conditions on these activities that are considered appropriate in the circumstances. ...

The transactions between Profitco and Lossco, which are related corporations, would not therefore be considered an abuse of the Act read as a whole. ...