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The economic substance test first reverses what some would regard as the existing default approach towards dealing with economic substance, arising from Canada Trustco, where a lack of economic substance is generally considered to be irrelevant, unless the provisions otherwise indicate that the transaction is inappropriate. ... This also raises the question of when Jane is considered to be “in the group.” ... I do appreciate that that came in at 25% and went up to 50% and then added on a prohibition on government contracts for those considered subject to the GAAR or not reported, but we did 25%. ...

CRA Response to Q.9(a) The Supreme Court of Canada considered the concept of profit in Canderel Ltd. v. ... That part will be considered to be the amount which is reasonable in light of the circumstances. ... The CRA is of the view that a “5 to 7” or a team lunch of a social nature could be considered as a type of social activity. ...

In such a scenario, could part of the services rendered by USco be: A. considered “services rendered in Canada” for purposes of Regulation 105; and B. considered “services… provided in that other State" for purposes of Article V:9(b) of the Canada-U.S. ... CRA document 2018-0776661I7 indicates that a miner who receives a bitcoin for validating transactions will be considered as having rendered a service. ... T1134 Missing Substantial Information (for 2021 and later taxation years) In technical interpretation 2019-0791541I7 the CRA indicated that an information return missing substantial information will be considered invalid, and therefore, will not be considered to have been filed. ...

All interest payments would then be considered to be “participating debt interest” as of the time a contingent or dependent amount is paid or payable. ... Where a debt bears only simple interest, any accrued and unpaid simple interest itself will not be considered to be an outstanding debt to a specified non-resident. ... In the situation submitted, the determination not to make an election will generally not be considered to have been made using reasonable efforts. ...

Notes from Presentation Trade receivables generally would be considered to arise in the ordinary course of business. ... Treaty, CRA has considered many strategies designed to ensure that either Art. ... CRA position CRA considered the fixed base PE provision in para. (1) of Art. ...

The legislation requires the calculation of income that could reasonably be considered to contribute to the capital gain. ... The question to be asked is, what is the amount of income that would be considered to contribute to the gain? ... Thus, only a portion of that income could constitute the safe income that is considered to contribute to the gain. ...

S. 94(2)(t) applies to expunge the contribution after the time of sale, so that thereafter, the contribution is considered to have never occurred. ... If this test is satisfied, then the business is considered an Excluded Business and the TOSI rules do not apply by virtue of the amount being an Excluded Amount. ... CRA concluded that the specified individuals could be considered to be actively engaged. ...

Furthermore, pursuant to the Technical Explanation to the 2007 Protocol to the Treaty, where Article IV(6) applies to deem a U.S. resident to be considered to derive a Canadian-source dividend, such dividend is considered as being paid to that U.S. resident. As such, dividends paid by the ULC in the example provided above would be considered as being paid to USCo1 and USCo2. ... The above comments should be considered whenever there is a conversion, from a Canadian tax perspective, from a partnership to a corporation. ...

However, travel between RPEs is considered employment-related. It is a question of fact whether a particular location is considered a RPE. ... (b) Home office A home office may be considered an RPE of an employee. ... Relief from a gross negligence penalty assessed under the Act can be considered under subsection 220(3.1). ...

., from the time of the sale forward, the contribution is considered to have never occurred). ... Accordingly, the other factors used to determine if the specified individual is actively engaged in the activities of the business must be considered. ... That being said, there are certain questions of fact and law that must be considered. ...