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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. 55. ...

The application of GAAR should always be considered, even if a GAAR Ruling is not being requested. ... The application of GAAR must be considered even if a GAAR Ruling has not been requested. ... Alternative transactions will not be considered at any time during the Pre-ruling Consultation. ...

In order to be considered, a request must follow the steps noted in “Making a Request” above. ... LLCs can be considered fiscally transparent for United States tax purposes. ... As a general rule, a request for an agreement will be considered on a prospective basis. ...

The CRA's responsibilities Under the Canada Pension Plan and the Employment Insurance Act, the CRA is responsible for determining: whether or not an individual's employment is pensionable under the Canada Pension Plan or insurable under the Employment Insurance Act; the amount of pensionable or insurable earnings; whether or not Canada Pension Plan (CPP) contributions and employment insurance (EI) premiums are payable; how many hours an insured person has in insurable employment; how long an employment lasts, including the dates on which the employment began and ended; the amount of CPP contributions and EI premiums payable; who is the employer; whether or not employers are considered to be associated for the purposes of the Employment Insurance Act; and the refund amount. ...

For Michel's TFSA contributions to be considered a qualifying transfer, with no tax consequences, Bank "A" must make a direct transfer of funds to Bank "B". ...

Assignment of purchase and sale agreements for grandparented housing in Prince Edward Island Where a written agreement of purchase and sale for grandparented housing is assigned to another person (assignee), the housing will remain grandparented if the assignee receives ownership and possession of the grandparented housing under the agreement with the original builder after March 2013 and: there is no novation of the agreement; the purchaser and the original builder are dealing at arm's length and are not associated for GST/HST purposes; the original builder does not reacquire by way of sale any legal or beneficial interest in the housing; and a person who is not dealing at arm's length (aunts and uncles are considered to be related to their nieces and nephews under these rules) with, or who is associated with, the original builder does not acquire by way of sale any legal or beneficial interest in the housing. ...

Assignment of purchase and sale agreements for grandparented housing in Ontario Where a written agreement of purchase and sale for grandparented housing is assigned to another person (assignee), the housing will remain grandparented if the assignee receives ownership and possession of the grandparented housing under the agreement with the original builder after June 2010 and: there is no novation of the agreement; the purchaser and the original builder are dealing at arm's length and are not associated for GST/HST purposes; the original builder does not reacquire by way of sale any legal or beneficial interest in the housing; and a person who is not dealing at arm's length (aunts and uncles are considered to be related to their nieces and nephews under these rules) with, or who is associated with, the original builder does not acquire by way of sale any legal or beneficial interest in the housing. ...

Invalid requests What is considered an invalid request? Requests made while an objection or appeal is in progress What will happen to your relief request when you have also filed an objection or appeal to an assessment and the objection or appeal is still in progress? ...

Redeterminations In addition to deductions or credits, you can also ask the CRA to redetermine the following amounts that are considered either as a payment on account of tax or overpayment of tax: Canada Child Tax Benefit (CCTB) payments available to eligible individuals for qualified dependents; goods and services tax/harmonized sales tax (GST/HST) credit available to eligible individuals; refundable medical expenses supplement available to eligible individuals; working income tax benefit (WITB) available to eligible individuals; working income tax benefit (WITB) disability supplement available to eligible individuals; refundable Quebec abatement for income earned in Quebec by an individual resident in Quebec; refundable investment tax credit available to taxpayers; refundable First Nations abatement for individuals who are subject to income tax legislation of certain First Nations; the tax credit that a beneficiary of a mining reclamation trust can claim; the tax credit that certain beneficiaries can claim for the Part XII.2 tax paid by a trust; and the tax credit a Canadian partnership flows through to its partners for the Part XII.2 tax paid by a trust. ...

When accepted by the CRA, a late or amended election will be considered to have been made at the time it was required to be made. ...