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Q7: Deemed Resident Trust and CCPC Status A trust which meets the conditions of section 94 is considered resident for certain purposes of the Act. ... Since subsection 94(3) does not state that a deemed resident trust is considered resident for purposes of determining control, we would imagine that the corporation would not be considered Canadian controlled. ... Q15: Trust and Estates Issues Can the CRA provide an update on some of the recent issues that it has considered relating to trusts and estates? ...

Thus, an agreement that is not an unanimous shareholder agreement would not generally be considered in determining de jure control of the corporation. ... It is considered to be one of the hallmarks indicative of a genuine intergenerational business transfer. ... The result is that the termination of the Bare Trust would not be considered to result in a disposition of the property held by the Bare Trust. ...

Where the election is not included with the income tax return filed, the election is considered late. ... Is the trust considered not to deal at arm’s length with Parent such that paragraph 43.1(2)(b) will apply? ... If an individual is not considered a factual resident of Canada, they may still be considered a deemed resident under s. 250(1). ...

Q.18(b) Is efiling of T4s and T5s being considered by CRA, instead of web uploads of.XML files? ... If so, which forms are being considered for the use of electronic signature? ... Q.20(d) How should a taxpayer handle GST (or HST) when selling NFTs that are considered inventory? ...

As an example, a U.S. limited liability limited partnership or U.S. limited liability company is considered to be a corporation for Canadian tax purposes but is considered as fiscally transparent or as a partnership by default under U.S. tax law. ... US LP is considered a flow-through entity for U.S. income tax purposes, but is not disregarded. ... LLC is not considered to be a resident of the U.S. for purposes of the Treaty. ...

Taxpayers who do not engage in abusive transactions. maintain an effective tax control framework. and are open and transparent with the CRA, are considered low-risk. ... Those that push the envelope and engage in abusive tax avoidance, for example, are considered higher-risk from a non-compliance perspective. ... Factors that may be considered include the level of non-compliance, large unexplained tax reserves, and potential tax at risk. ...

Would its principal business be considered to be lending, and would income tax concepts be applied so that it would be considered to be earning income from property rather than having a business. ... Although revenues received by a person are considered in determining the principal business of the person, they are not the only factor that will be considered and is not itself a determinant factor. ... Comments from the CBA will be considered in the context of this review. ...

Although the committee considered that the transaction circumvented the integration principle, it recommended that the GAAR not be applied. ... Why we changed our position is that we did not want plans to be considered offside on the basis of nominal or incidental non-METC coverage. ... Assume that FA #2 acquires a 95% interest in Target such that Target is considered to be a partnership for US tax purposes. ...

In the case of taxpayers who are considered non-filers, there is no statute-barred limit to observe. ... An emission allowance is a right and, as such, is considered intangible personal property. ... Where the option or contract can only be settled in money it may be considered a financial instrument. ...

Before it can be concluded that an amount is payable within the meaning of subsection 104(13), subsection 104(24) must be considered. ... In particular, is the gain considered to be from a source in Australia for purposes of computing the foreign tax credit? ... Prior to the time when the estate administration is complete, the executors are generally considered to hold legal and beneficial ownership of the estate property and the estate is still considered to be in existence. ...