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Archived CRA website

ARCHIVED - Electing under section 217

Generally, the non-resident withholding tax is considered your final tax liability on the income. ... If you send us your return after the due date, your election will not be considered valid. The 23% non-resident withholding tax will be considered the final tax liability. ...
GST/HST Interpretation

7 April 2014 GST/HST Interpretation 139981r - Application of the GST/HST to the distribution of private placements by investment dealers

Whether services performed by [the Dealer] are considered to be a single supply or multiple supplies under each agreement is a question of fact. ... If it is determined that multiple supplies are being provided by a person, the possible application of sections 138 and 139 should be considered. ... If the predominant element of the single supply is determined to be a financial service, then the supply as a whole will be considered a financial service. ...
GST/HST Interpretation

13 January 2022 GST/HST Interpretation 187184 - Application of GST/HST to mutual fund trailing commissions in the mutual fund industry

For GST/HST purposes, the manager is considered to make a supply of its services to the fund. ... If it is determined that multiple supplies are being provided by a person, the possible application of sections 138 and 139 must also be considered. ... This would be considered a financial service of arranging for the purchase of financial instruments. ...
GST/HST Interpretation

16 October 1997 GST/HST Interpretation HQR0000011 - Returnable Containers

The amounts of tax are considered as included in the deposits given for the containers in order to keep the integrity of the deposit amounts intact. ... The amounts paid as a commission or donation are considered as not being consideration for the acquisition of the containers. ... Or would the premium be considered a taxable supply by a registered customers, such as handling or commission? ...
Current CRA website

Guidelines for Treaty-Based Waivers Involving Regulation 105 Withholding

Where the waiver applicant meets the conditions of test A, the following exceptions will not be considered. ... If gross income is less then CAN$15,000 for the calendar year, a waiver may be considered based on these guidelines. 4. ... Payments to sub-contractors will be considered for deduction under an alternative income and expense waiver application. ...
Archived CRA website

ARCHIVED - Expenses of Issuing or Selling Shares, Units in a Trust, Interests in a Partnership or Syndicate and Expenses of Borrowing Money

It is a question of fact whether a particular fee is reasonably considered to relate solely to the year. For example, a one-time fee related to a loan with a term longer than one year, such as a loan-structuring fee or loan-placement fee, is not reasonably considered to relate only to the year in which the loan was made. ... In that situation, the expense will normally be considered to be incurred in the course of the issuance. ...
Archived CRA website

ARCHIVED - Electing under section 217

Generally, the non-resident withholding tax is considered your final tax liability on the income. ... If you send us your return after the due date, your election will not be considered valid. The 23% non-resident withholding tax will be considered the final tax liability. ...
Current CRA website

Internal Audit – Administered Activities Accounts Receivable Write-Offs

When a debt cannot be collected, it is considered an uncollectible debt. ... The Collections Directorate reviews accounts held in inventory for more than 5 years, which are considered aged accounts. ... Procedures could be improved by defining what is considered “timely”. ...
Archived CRA website

ARCHIVED - Federal Income Tax and Benefit Guide - 2018 - General information, identification and other information

You resided outside Canada on December 31, 2018, but kept significant residential ties with Canada; you may be considered a factual resident of Canada. ... You resided outside Canada on December 31, 2018, and are considered a deemed resident or a non-resident of Canada. ... You are still considered to have a spouse or common-law partner if you were separated involuntarily (not because of a breakdown in your relationship). ...
Old website (cra-arc.gc.ca)

Residential Real Property - Deemed Supplies

The agreement between the builder and the individual is considered to be an agreement of purchase and sale. A sale is considered to have occurred when possession of the complex is given to the individual under an agreement to transfer the ownership of the complex. ... Cases not meeting this general rule are not necessarily disqualified from the election; each can be considered on its own merits. 56. ...

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