Search - considered

. ¶1.77 is revised to add a reference to paragraph (n) of the term disposition in subsection 248(1) (as added by S.C. 2013, c. 34, s. 358(12)) which states that, among other things, shares of a predecessor corporation held by another corporation that are cancelled on an amalgamation will not generally be considered to have been disposed of as a result of the amalgamation. ... That decision considered whether, because of paragraph 87(7)(d), subsection 78(1) applied to the amalgamated corporation in respect of unpaid interest on a debt that was inherited by the amalgamated corporation from a predecessor corporation. ¶1.59 was added to address the CRA's position regarding whether an amalgamated corporation will, for the purposes of subsections 40(10) and 40(11), be considered to have realized a gain that was deemed under paragraph 111(4)(e) and subsection 111(12) to have been realized by a predecessor corporation. ¶1.60 was added to address the CRA's position regarding the application of the tracing principle under paragraph 20(1)(c) to determine whether an amalgamated corporation would be entitled to deduct under paragraph 20(1)(c) interest paid or payable by the amalgamated corporation on money that was originally borrowed by a predecessor corporation. ¶1.62 was added to address the CRA's position regarding the ability of an amalgamated corporation to file, on behalf of a predecessor corporation, information returns and slips under various provisions of the Act. ¶1.65 (formerly addressed in ¶34 of IT-474R2) has been revised to reflect the CRA's position regarding the collection of a predecessor corporation's tax debts from the amalgamated corporation. ¶1.67 was added to address the CRA's position regarding whether subparagraph 8503(3)(a)(i) of the Regulations will apply following a qualifying amalgamation to include the period throughout which an employee of the new corporation was employed by a predecessor corporation. ¶1.68 (formerly addressed in ¶36 of IT-474R2) has been revised to clarify that a shareholder's exchange of shares of a predecessor corporation for shares of the amalgamated corporation constitutes a disposition for purposes of the Act. ¶1.69 (formerly addressed in ¶36 of IT-474R2) has been revised to include a reference to the circumstances where a share of a new corporation received by a non-resident on an amalgamation constitutes taxable Canadian property under subsection 87(4). ¶1.75 and 1.76 (formerly addressed in ¶40 of IT-474R2) have been revised to add a reference to similar gifting rules contained elsewhere in the Act and clarify that the 87(4) exception applies on a shareholder-by-shareholder basis. ...

Filing allows you to receive any benefits and credits you may be eligible for, such as: goods and services tax (GST) / harmonized sales tax (HST) credit Canada workers benefit Canada child benefit related provincial or territorial payments The tax-filing deadline for most individuals is April 30, 2022 Since April 30, 2022, falls on a Saturday, your return will be considered filed on time in either of the following situations: we receive it on or before May 2, 2022 it is postmarked on or before May 2, 2022 You have until June 15, 2022, to file your tax return if you or your spouse or common law-partner are self-employed. The payment deadline is April 30, 2022 Since April 30, 2022, falls on a Saturday, your payment will be considered paid on time if we receive it, or it is processed at a Canadian financial institution, on or before May 2, 2022. ... Your payment will also be considered paid on time if we receive it, or it is processed at a Canadian financial institution, on or before May 2, 2022. ...

Property used more than 50% of the time for the purpose of gaining or producing gross revenue that is rent, royalty or leasing revenue is considered to be used principally for that purpose. ... Where a flat amount is charged for the use of rental property and leasing property combined, and no allocation of income is considered necessary, CCA may be claimed in respect of either or both properties provided the aggregate CCA claimed does not exceed the combined rental and leasing income. ... For purposes of the gross revenue test of a corporation where the corporation has an interest in a partnership, it is considered that the gross revenue of the partnership, to the extent of the corporation's profit sharing percentage thereof, flows through to the gross revenue of the corporation. ...

The first thing to know is that the CRA has prescribed rates under section 7306 of the Income Tax Regulations that are considered to be reasonable. ... Scenario – Flat Rate Here the CRA notes that: The allowance is not considered reasonable since it is not connected to kilometres driven. ... Where an employee has driven their automobile for business purposes more than 50% of the time in 2019, they may also be considered to have used their vehicle more than 50% for business purposes in the 2020 and 2021 tax years. ...

The transfer of the Settlement Payment to the RRSP or RRIF to correct the error will not be considered a contribution, and no deduction will be permitted for the amount transferred. ... If you received the Settlement Payment in respect of shares held in your RRSP or RRIF and choose not to transfer the cash and shares to your RRSP or RRIF, the cash payment and the fair market value of the shares will be considered income and must be included on your tax return as an RRSP or RRIF benefit received in the year. 2. ... Since you no longer owned any of your Original Shares when you received the Settlement Payment, you are considered to have received additional proceeds of disposition from having disposed of your Original Shares. ...

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. ...

Only requests relating to tax years ending in any of the 10 calendar years before the year you make the request will be considered. For example, a request made in 2006 must relate to the 1996 or a subsequent tax year to be considered. ... For example, a request made in 2006 must relate to the 1996 or a subsequent tax year to be considered. ...

When recommendations for corrective action in a prior audit relate to areas considered being at risk, more in depth follow-up audits are included in subsequent CAEB annual business plans. ... The remaining 13 action plans (11%) that were not considered complete relate to three audits: Use of Legislative Enforcement Provisions (May 2006); Tax Information Exchange MOU with Revenu Québec (February 2006); and Information Exchange MOU with Human Resources Development Canada (January 2005). ... In recognition of the lengthy renewal process and the number of stakeholders involved, the progress made in completing these is considered satisfactory. ...

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 Footnote 3 and the transfer price for this transaction is tested using a cost-based method Footnote4 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 Policy When a cost-based transfer pricing methodology is used to determine the transfer price of goods, services, or intangibles sold by a Canadian taxpayer to a non-arm's length non-resident person and the Canadian taxpayer receives government assistance, the cost base should not be reduced by the amount of the government assistance received, unless there is reliable evidence that arm's length parties would have done so given the specific facts and circumstances. ... 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, Footnote5 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 To establish whether a transfer price is consistent with the arm's length principle, the most appropriate transfer pricing methodology must be used. ... 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. ...