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When completing the T3 return, follow the instructions in the T3 guide, and make sure that you: (a) complete all of the identification area on page 1; (b) identify the trust as a communal organization; (c) do not deduct any amount for salaries, wages, or benefits of any kind paid to any members of the congregation when calculating the trust's taxable income; (d) if you make an election regarding taxable income, determine the trust's modified taxable income; (e) if you make an election regarding donations and gifts, enter on Schedule 9, Summary of Income Allocations and Designations to Beneficiaries, the total amount of charitable donations and Crown and cultural gifts designated to members of the congregation; and (f) if the trust is allocating business, farming, or fishing income, enter on Schedule 9, in the area called "self-employment earnings," the total amount of business, farming, and fishing income allocated, since it is considered to be self-employment income for CPP contributions. 20. ... The income the trust allocates will be considered to be the income of the beneficiaries for the year from a trust. ... However, business income allocated by the trust is considered to be self-employment earnings for Canada Pension Plan contributions. 24. ...

For example, a business that was considered to be operating primarily to provide instruction in languages in a fiscal year and that intends to continue to operate in the same manner would be considered to be operated primarily to provide instruction in languages in the following fiscal year. However, if the portion of the business’s total annual revenues that is derived from language course fees/tuition or that can be attributed to instruction in these courses falls to 50% or less during the following fiscal year, the business would no longer be considered to be operated primarily to provide instruction in languages in the next fiscal year. ...

An entity must meet all of the conditions set out in this definition to be considered a non-profit organization for the purposes of the Act. ... A non-profit organization is considered to have been "established primarily for the benefit of organized labour" if it was established primarily to provide some advantage to organized labour, such as: a trade union as defined in section 3 of the Canada Labour Code; a trade union as defined in any provincial act that provides for the investigation, conciliation, or settlement of industrial disputes; an association of public servants whose primary object is to promote the improvement of the members’ conditions of employment or work; or a parity or advisory committee or similar body. 15. ... Therefore, Organization A is considered to have been "established primarily for the benefit of organized labour". ...

A financial institution (FI) would generally be considered to be an SLFI throughout a reporting period in a fiscal year that ends in a particular taxation year of the FI if it is an LFI described in any subparagraphs 149(1)(a)(i) to (x) at any time during the particular taxation year, and the FI has a permanent establishment in a participating province and a permanent establishment in any other province, at any time during the taxation year. ... Insurance companies and fraternal benefit societies that are registered federally or provincially are generally considered to be LFIs. ... Person whose principal business is the lending of money or the purchasing of debit securities or a combination thereof – A person that carries on business principally as a finance company, acceptance company, factor, venture capitalist, or a loan, mortgage or investment company is considered to be an LFI. ...

If you lived outside Canada on December 31, 2002, but maintained residential ties with Canada, you may be considered a factual resident of a province or territory. ... However, this may not apply if you were a factual resident who, under a tax treaty, is considered to be a resident of another country. ... Deemed resident- You are a deemed resident for tax purposes if you did not establish residential ties in Canada, but you stayed here for 183 days or more in 2002 and, under a tax treaty, you were not considered a resident of another country. ...

Conclusion: The enhancements relating to the new accounts created for PEI were considered to be appropriate and mapped to the correct RL accounts. ... Based on our sample review of the applicable changes, the enhancements relating to the new accounts created for PEI were considered to be appropriate. ... Conclusion The enhancements relating to the new accounts created for PEI were considered to be appropriate and mapped to the correct RL accounts. ...

Among other things, these years may be in the process of a risk assessment, they may be subject to an ongoing audit or they may eventually be considered for audit. ... Requests may be considered at a later time, provided they are submitted as soon as possible during the MAP process in order to allow the competent authorities sufficient time to review and consider the request before the conclusion of the competent authority negotiations. ... A competent authority settlement is not considered a precedent for either the taxpayer or the CRA with respect to filing positions, assessments, reassessments or competent authority negotiations on the same issues for subsequent taxation years. ...

" The criteria to consider in determining the most appropriate method to the circumstances of the case are: "(…) the respective strengths and weaknesses of the OECD recognised methods; the appropriateness of the method considered in view of the nature of the controlled transaction, determined in particular through a functional analysis; the availability of reliable information (…) needed to apply the selected method and/or other methods; and the degree of comparability between controlled and uncontrolled transactions, including the reliability of comparability adjustments that may be needed to eliminate material differences between them. ... Although not compulsory, this "typical process" is considered good practice by the OECD. ... In addition, in order to correct a misquote of the Guidelines, the last sentence of this paragraph is revised to read "The OECD Guidelines identify two exceptional situations where disregarding a transaction would be considered." ...

Subsection 247(4) of the Act deems a taxpayer not to have made reasonable efforts to determine and use arm’s length transfer prices or allocations for purposes of the penalty provision in subsection 247(3) of the Act, for the taxation years (or fiscal periods) under review, unless the taxpayer complies with the following three requirements: The taxpayer makes or obtains, on or before the taxpayer’s documentation-due date (defined in subsection 247(1) of the Act) for the taxation year or fiscal period in which the transaction is entered into, records or documents that provide a description that is complete and accurate in all material respects of: the property or services to which the transaction relates; the terms and conditions of the transaction and their relationship, if any, to the terms and conditions of each other transaction entered into between the participants in the transaction; the identity of the participants in the transaction and their relationship to each other at the time the transaction was entered into; the functions performed, the property used or contributed and the risks assumed for the transaction by the participants in the transaction; the data and methods considered and the analysis performed to determine the transfer prices or the allocations of profits or losses or contributions to costs, as the case may be, for the transaction; and the assumptions, strategies and policies, if any, that influenced the determination of the transfer prices or the allocations of profits or losses or contribution to costs, as the case may be, in respect of the transaction. ... Documentation provided to the CRA under different circumstances or obligations (such as documentation provided with an APA submission or in a return) is not considered documentation previously provided to the CRA for the purposes of the current request for contemporaneous documentation. ... If these conditions are met and the documentation does exist, it will then be considered to have been provided within three months after the request for contemporaneous documentation was served. ...

Some of the courses listed above may require a combination of courses to be considered equivalent depending on the recognized postsecondary institution. ... However, if an acceptable specialization in accounting is required for a position, an employee who has acquired rights but does not have the acceptable accounting courses cannot be considered for the position. ... Candidates possessing a bachelor’s degree in engineering or computer science with an acceptable combination of education, training and/or experience will be considered as meeting the education standard. ...