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Current CRA website

Not dealing at arm's length for purposes of the Employment Insurance Act (EIA)

The meaning of “not dealing at arm's length” For the purposes of the EIA, an employee and an employer may be considered not to be dealing at arm's length with each other. ... Therefore, any employment between related persons is considered not insurable. ... In situations where the parties are non-related, the same circumstances of employment as those with related persons have to be considered. ...
Current CRA website

Chapter 1 - 147.1(1), 248(1), 8300(1), 8500 – Definitions

Types of leave other than those listed above may also be considered for post-reform service on a case-by-case basis. ... However, not every plan in which more than one employer participates is considered a MEP. ... For example, the pension (including bridging benefits) payable to a member and the pension payable on death to the member's spouse are considered to be retirement benefits, while lump sum benefits payable after the death of a member are not considered to be retirement benefits. ...
Current CRA website

Income Tax Audit Manual

A taxpayer who engaged in a transaction that is considered an adventure or concern in the nature of trade is not necessarily considered to be carrying on a business or to have carried on a business. ... Losses are considered exclusive of expenses that would be disallowed under paragraphs 18(1)(a), (h), or section 67. ... A self-employed individual uses discretion to produce a given result in a manner considered most appropriate. ...
Current CRA website

Application of Profit Test to Carrying on a Business (Revised Sept 30, 1998)

There must be a reasonable expectation of profit from the activities engaged in by such partnerships, proprietorships and personal trusts in order for the activities to be considered commercial activities. ... There are several issues surrounding the concept of profit as it relates to the public sector and the criteria provided in this policy should not be relied upon to determine whether an organization would be considered to be non-profit. ... The specific factors to be considered in making such a determination will differ with the nature and extent of the activity or undertaking. ...
Current CRA website

Anti-avoidance Rules

Pursuant to subsection 274(3), an avoidance transaction is a transaction that alone, or as part of a series of transactions, would result, directly or indirectly, in a tax benefit were it not for section 274, unless the transaction can reasonably be considered to have been undertaken or arranged primarily for bona fide purposes other than to obtain the tax benefit. 7. Pursuant to subsection 274(4), subsection 274(2) does not apply in respect of a transaction where it may reasonably be considered that the transaction would not result, directly or indirectly, in a misuse of the provisions of Part IX or in an abuse of Part IX as a whole. Tax planning or transactions that are carried out for purposes other than obtaining tax benefits but which minimize the payment of tax, as compared to other transactions which would achieve the same purpose but which would result in higher tax liability, may not be considered to be avoidance transactions. 8. ...
Current CRA website

Commercial Real Property - Sales and Rentals

., if the proceeds from the sale would be considered a capital gain or capital loss for income tax purposes. ... While the lessee is generally not considered to be responsible for paying property taxes, the lessee is liable for the payment of the rent. ... If the landlord makes a cash payment to the lessee as an inducement to enter into the lease, the lessee is considered to have made a taxable supply to the landlord. ...
Current CRA website

Information for Students – Educational Institutions outside Canada

If you are considered a factual or deemed resident of Canada for tax purposes, and a resident of another country according to a tax treaty Canada has with the other country, you may be considered a deemed non-resident of Canada. ... The following general information is for students who are considered to be factual or deemed residents of Canada. ... Distances that are beyond daily travel, such as airline travel three times a semester, are not considered a commute. ...
Current CRA website

Application of Profit Test to Carrying on a Business (Revised Sept 30, 1998)

There must be a reasonable expectation of profit from the activities engaged in by such partnerships, proprietorships and personal trusts in order for the activities to be considered commercial activities. ... There are several issues surrounding the concept of profit as it relates to the public sector and the criteria provided in this policy should not be relied upon to determine whether an organization would be considered to be non-profit. ... The specific factors to be considered in making such a determination will differ with the nature and extent of the activity or undertaking. ...
Current CRA website

Information for Students – Educational Institutions outside Canada

If you are considered a factual or deemed resident of Canada for tax purposes, and a resident of another country according to a tax treaty Canada has with the other country, you may be considered a deemed non-resident of Canada. ... The following general information is for students who are considered to be factual or deemed residents of Canada. ... Distances that are beyond daily travel, such as airline travel three times a semester, are not considered a commute. ...
Current CRA website

Commercial Real Property - Sales and Rentals

., if the proceeds from the sale would be considered a capital gain or capital loss for income tax purposes. ... While the lessee is generally not considered to be responsible for paying property taxes, the lessee is liable for the payment of the rent. ... If the landlord makes a cash payment to the lessee as an inducement to enter into the lease, the lessee is considered to have made a taxable supply to the landlord. ...

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