Search - considered

Canada Carbon Rebate for Small Businesses You may be looking for: Canada Carbon Rebate for individuals Reporting the Canada Carbon Rebate for Small Businesses on your T2 corporation income tax return Under the current legislation, the Canada Carbon Rebate for Small Businesses is considered assistance received from a government and is subject to taxation. ...

Since March 30, 2024 falls on a Saturday, a T3 return will be considered filed on time if the CRA receives it, or it is postmarked, on or before April 2, 2024 (the next business day). ...

Find out how you should track and report all your tips and gratuities In Canada, the amount you earn in tips and gratuities is considered to be income, and you must report all of it on your tax return. ...

As a general rule, a taxpayer who takes commodity futures positions in, or who has transactions in, a commodity connected with a business, is considered to be trading as part of the business operations and the comments in 3 above apply. ... As an example, a jeweller who buys 100 ounces of gold for a business (a normal amount for that business) and also makes additional purchases of 1600 ounces of gold, or of futures contracts representing 1600 ounces of gold, as a speculation for his or her own account, may be viewed as a speculator with respect to the additional purchases when all the facts of the situation are considered. ... However, the comments in 4 above must be applied in respect of each member of the partnership and if one member can be considered an insider then the income treatment is required for the partnership. 18. ...

Part 1 – Aggregate investment income calculation The aggregate investment income is the aggregate world source income calculated as follows: add the eligible portion of the taxable capital gains for the year that is more than the total of: the eligible portion of allowable capital losses for the year; and the net capital losses from previous years which are applied in the year; total income from property (including income from a specified investment business carried on in Canada other than income from a source outside Canada) from which the following amounts have been deducted: exempt income; AgriInvest receipts (include the Quebec amount); taxable dividends deductible after deducting related expenses; and business income from an interest in a trust that is considered property income under paragraph 108(5)(a); deduct total losses for the year from property (including losses from a specified investment business carried on in Canada other than losses from a source outside Canada). ... Part 2 – Foreign investment income calculation The foreign investment income is all income from only sources outside of Canada calculated as follows: add the eligible portion of the taxable capital gains for the year that is more than the eligible portion of allowable capital losses for the year; and the total income from property from a source outside Canada from which the following amounts have been deducted: exempt income; taxable dividends deductible after deducting related expenses; and business income from an interest in a trust that is considered property income under paragraph 108(5)(a); deduct the total losses for the year from property from a source outside Canada. ... To claim a dividend refund, you have to have made an actual payment to the shareholders, unless the dividend is considered paid (a deemed dividend). ...

The following is a common scenario: A Canadian resident corporation (CanCo) provides products or services to a non-arm's length non-resident corporation (ForCo); CanCo is considered the tested party [3] and the transfer price for this transaction is tested using a cost-based method; [4] CanCo receives financial assistance from one or more government agencies or programs; In calculating the cost base for transfer pricing purposes, CanCo reduces the cost base by an amount equal to the government assistance received. ... The following are some of the items that may be considered: identification of all characteristics that are relevant to the market or industry; the accounting treatment of the government assistance in both the tested party and any comparable identified, for example, whether the government assistance is deducted from the costs or it is presented separately, [5] since not considering differences such as the accounting treatment can affect profit level indicators; whether and to what extent the government assistance is passed on to arm's length customers or suppliers in that particular market or industry; when the government assistance is not fully passed on to arm's length customers or suppliers, the manner in which arm's length enterprises operating under similar circumstances would allocate such benefits between them through further enquiry; any other relevant information. ... For example, when the government assistance can be considered as highly integrated to the operations and significantly affects the economically relevant market conditions, a transactional profit split method may be the most appropriate transfer pricing method. ...

Penalty referrals The application of penalties under subsection 247(3) must be considered in all cases where the total of transfer pricing capital and income adjustments for a taxation year: exceed 10% of gross revenue for the year as calculated under subparagraph 247(3)(b)(i); or exceed $5,000,000. ... At that time, the auditor will advise the taxpayer that the application of paragraphs 247(2)(b) and (d) are being considered with respect to the transactions under review. ... The taxpayer’s representations and the additional information will be considered when completing the formal referral report. ...

“Related persons” are not considered to deal with each other at arm’s length. ... Deemed disposition This expression is used when a person is considered to have disposed of a property, even though a sale did not take place. Deemed proceeds of disposition This is an expression used when a person is considered to have received an amount for the disposition of property, even though the person did not actually receive that amount. ...

Pursuant to subsection 104(24), an amount is not considered to be payable in a taxation year unless it is paid in the year to the person to whom it is payable or the person to whom it is payable is entitled in the year to enforce payment thereof. ... It should be noted that foreign accrual property income of a non-resident trust is included in the income of a beneficiary pursuant to paragraph 104(13)(c) to the extent that the amount may reasonably be considered to have become payable to a beneficiary within the meaning of subsection 104(24). ... The amounts required to be included in computing the income of a beneficiary for a taxation year under subsections 104(13) and 105(2) are considered to have been earned by the beneficiary on the last day of the taxation year of the trust and are thus in respect of the taxation year or years of the trust which ended in the taxation year of the beneficiary. ...

Once such an amount on account of the sale price exceeds the adjusted cost base of the shares (as reduced by any previous such amounts), the excess is considered to be a capital gain that is realized at the time that that amount became determinable, and the adjusted cost base becomes nil. ... Where the sale agreement stipulates a minimum amount payable by the purchaser in any event, that amount is considered to become determinable by the vendor at the time of the sale. ¶ 6. ... For the purposes of this bulletin, an agreement that merely determines when amounts are to be paid, as opposed to determining the quantum of proceeds, is not considered to be an earnout agreement. ¶ 9. ...