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However, the Act specifies that, for purposes of that provision, certain amounts paid or credited to a non-resident are not considered "management or administration fees or charges," provided that they are reasonable in the circumstances. ... Where Canada has a treaty with another country but it contains no specific article on management or administration fees, any such fees paid to a resident of that country will, to the extent they are reasonable, be considered to be covered by the treaty article dealing with business (industrial or commercial) profits. ... If a person who is considered to be a resident of Canada for tax purposes has a foreign mailing address during a period of temporary absence from Canada, that person must obtain confirmation of residency in Canada from a taxation office in order to not have the PAGE 42 non-resident withholding tax withheld from payments. ...

Section 252 of the ITA extends the meaning of these terms to encompass other individuals who might otherwise not be considered to fit the normal use of the term. ... As a result, the personal use of the passenger vehicle by an employee or shareholder, or a person related to the employee or shareholder, is not considered to be use in the registrant's commercial activities. ... As a general rule, a person is considered a large business if the person is a registrant and the person has a threshold amount for the recapture of input tax credits (RITCs) of more than $10 million in their last fiscal year that ended before the recapture period, or the person is one of the following financial institutions, or a person that is related to one of the following financial institutions: a bank; a credit union; a corporation that is licensed or otherwise authorized under the laws of Canada or a province to carry on in Canada the business of offering to the public its services as a trustee; an insurer or any other person whose principal business is providing insurance under insurance policies; a segregated fund of an insurer, an investment plan or the person is the Canada Deposit Insurance Corporation. ...

The retirement savings rollover to an RDSP: will be considered a private contribution for the purpose of determining whether the RDSP is a PGAP, but will not attract grants; will be included in the taxable portions of RDSP withdrawals made to the beneficiary; and may not exceed, and will reduce the RDSP contribution lifetime limit. ... The education savings rollover to an RDSP: will be considered a private contribution for the purpose of determining whether the RDSP is a PGAP, but will not attract grants; will be included in the taxable portions of RDSP withdrawals made to the beneficiary; and may not exceed, and will reduce the RDSP contribution lifetime limit. ... Unless an election is filed with the issuer, the RDSP must be terminated and all amounts paid out of the plan by December 31 st of the year following the first calendar year throughout which the beneficiary is no longer considered to have a severe or prolonged impairment in physical or mental functions that qualified him or her for the DTC. ...

However, under restricted circumstances, rights to use real property supplied by way of licence or concession for a limited period could be included under Class 14 and thus not be considered as capital property for the purposes of the GST/HST. ... Real property that is inventory (e.g., property acquired or held for the purpose of sale in the course of a business or in an adventure or concern in the nature of trade) is not considered to be capital property. ... If the use in commercial activities is 10% or less, the registrant is ineligible for an ITC on the property as a result of section 141 which deems that if the property is used 90% or more in activities that are not commercial activities, then none of the use is considered to be in commercial activities. ...

FY 2011-12 10% 21% FY 2012-13 50% 58% FY 2013-14 Strategies/Comments Definition of a location: A location is considered a facility that is occupied by CRA employees. ... Performance Measure RPP DPR Target Status Achieved Achieved Presence of a green meetings guide (optional for RPP 2011-12) Expected completion FY 2011-12 Yes: Adopted March 2012 Strategies/Comments Definition of adoption within the Green Meeting Guide: In order to be considered adopted, the guide will have senior management approval, be distributed and promoted throughout the CRA, and be posted on the national SD Web site. ... As a result, non-respendable non-tax revenues are considered to be earned on behalf of the Government of Canada. ...

As a result, non–respendable revenues are considered to be earned on behalf of the Government of Canada and are therefore presented as a reduction of the CRA's gross revenues. ... An allowance for doubtful accounts is recorded where recovery is considered uncertain. ... All other cases, excluding those assessed as unlikely to be lost, are considered contingent liabilities and the related amounts are disclosed whenever the amount of the contingency can be reasonably estimated. ...

Yes—completed March 2012 Total number of departmental locations with an EEE implementation plan fully implemented, expressed as a percentage of all locations, by the end of the given fiscal year. 100% Strategies and comments Definition of location A location is considered a facility that is occupied by CRA employees. ... (target 8.9 from 2010-13 FSDS) Performance measure Performance status Target status Achieved Presence of a green meeting guide Yes: adopted in March 2012 Strategies and comments Definition of adoption within the green meeting guide To be considered adopted, the guide will have senior management approval, be distributed and promoted throughout the CRA, and be posted on the CRA's sustainable development internal Web site. ... Strategic environmental assessment During the 2013-2014 reporting cycle, the CRA considered the environmental effects of initiatives subject to the Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals, as part of its decision-making processes. ...

As a result, non-respendable revenues are considered to be earned on behalf of the Government of Canada and are therefore presented as a reduction of the CRA's gross revenues. ... An allowance for doubtful accounts is recorded where recovery is considered uncertain. ... All other cases, excluding those assessed as unlikely to be lost, are considered contingent liabilities and the related amounts are disclosed whenever the amount of the contingency can be reasonably estimated. ...

As a final note, since direct sellers are the persons considered to be making the sale, they must ensure that they provide the proper documentary requirements. ... As such, the person is considered to have fallen under the small supplier's threshold of $30,000 since that date. ... The giving of a host gift would be considered a supply by way of sale of the property. ...

None of them are considered high risk. No further action is taken until the plan’s next full review. ... None of them are considered high risk. We send acknowledgment letters for the submissions. ... Some attendees also considered IPPs and plans where new past service is being added to be a priority. ...