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Has the CRA considered the entity classification for Luxembourg limited partnerships or special limited partnerships? ... Because Gabon and Ivory Coast are civil law jurisdictions and Quebec has a civil law system, it was considered appropriate to compare the characteristics of those foreign entities to the characteristic of partnerships formed under the Civil Code of Quebec. ... These are general conclusions, but every arrangement needs to be considered on its own merits. ...

CRA written response The CRA is of the view that a building is normally considered to be a single property unless it was legally subdivided into two or more separate properties. ... In the situation you described, the CRA is of the view that the sum of $50,000 that the vendor received could be considered as proceeds of disposition of his right under the promise. ... To determine whether or not the rights in a lease are an asset used principally in an active business carried on by the corporation, the use of the property which is the subject of the lease must be considered. ...

As indicated in paragraph 12 of Interpretation Bulletin IT-456R, [FN13: CANADA REVENUE AGENCY, Interpretation Bulletin IT-456R (archived), "Capital Property- Some Adjustments to Cost Base," July 9, 1990.] the CRA allows the actual loss on the properties considered to be redeemed or the average loss on each property multiplied by the number of properties considered to be reacquired to be the superficial loss in this case. ... (c) Is the GRE considered to have made the gift at the time of the CRT’s creation or when the capital interest in the CRT is actually delivered to the qualified donee? ... The eligible amount of a gift of a capital interest in a CRT could therefore be considered a charitable gift of the deceased individual (and not of the individual’s estate) for the purposes of subsection 118.1(3). ...

Question Where non-residents affected by the new GST/HST remote seller rules, that need to confirm the purchaser’s GST/HST registration number, what evidence will be considered satisfactory to satisfy the Minister that the non-resident seller obtained a particular number? ... The possible answers seem to be: (a) The AII will be available on the entire cost of the asset on its completion – it is considered “acquired” in its entirety only when it is completed (b) The AII will not be available if construction of the asset commenced prior to November 21, 2018 – it was considered “acquired” when construction commenced. ... (d) Some other possibility not considered above. Can the CRA confirm how the rules will apply for assets under construction? ...

In the above scenario, what parties would be considered NR1 and NR2, respectively, and what are their reporting obligations under subsection 237.4(4)? ... We often refer to a “90%” rule, but neither CRA nor the courts have ever considered 90% to be a strict threshold. ... Subsection 55(2) applies such that, for purposes of the Act, the deemed dividend is considered not to be a dividend and to be proceeds of disposition of the share. ...

Outside of financial hardship, can the CRA provide any examples of a taxpayer who has not exercised due diligence, but who would be considered eligible for penalty relief? ... The reasonability of allowances in excess of prescribed amounts can be considered in some circumstances. ... CRA Response (a) Please note that this is not being considered. This type of information is available only to the legal rep or the taxpayer. ...

However, where the seller is a partnership, the CRA looks at the partners on the basis that the partnership is not considered to be a person under s. 96 for purposes of s. 116. ... U.S. resident considered to derive Canadian-source dividends for purposes of the Canada-U.S. ... In response to the two questions, whether rulings or audit guidance can be provided or shared about files where the anti-avoidance rule has been considered, there is no such file. ...

In most situations, it is considered very unlikely that the “disaster clause” will apply, especially where there are many primary beneficiaries. ... Assume the loan can be considered debt. (3) The loan above is subsequently repaid in full. ... Since providing that answer, the Tax Court of Canada considered this issue in Hess 2011 TCC 360. ...

(a) [one estate] As a general matter, while an estate is under administration during its first 36 months, will it be considered a graduated rate estate in its entirety? ... A reasonable time will usually not be considered to extend beyond the end of the taxation year following the year in which the debt or obligation became payable by the trust. ... The deadline for the 2014 year was May 1, 2015 and any FI which does not meet those obligations may be subject to penalties and interest, and may be considered non-compliant. ...

Each owner is considered to have ownership proportionate to the fair market value of each distinct equity interest. ... Accordingly, the deceased's estate will be considered to be a contributor to the child's trust. ... Therefore, in the given instance, the deceased is also considered to be a contributor to the child's trust. ...