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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. ...

The Supreme Court of Canada considered the concept of profit in Canderel Ltd. v. ... Since expenses cannot be considered to be incurred by an individual who is not thereby obligated to pay a sum of money, the CRA is of the view that expenses paid are not necessarily expenses incurred by a taxpayer. ... For an expense to be considered to have been incurred for the purposes of paragraph 18(1)(a), it is not necessary that the expense be paid by the person incurring the expense. ...

This is because the non-resident third-party vendor is generally not considered to be carrying on business in Canada and the distribution platform operator is not considered to be the supplier of the goods. ... If a registrant changes the use of capital property in its commercial activities by 10% or more in a period, the change is considered significant and the change-in-use rule in subsection 206(2), 206(3) or 206(5), as applicable, comes into play. In determining whether a change in the use of capital property in business activities is significant, the cumulative effect of the changes should be considered. ...

That document needs to be in the record so that we all know precisely what is being considered. ...

Where penalties usually arise is from a failure to comply with subparagraphs (iv)-(vi)- i.e. the documentation is not complete and accurate regarding: (iv) the functions performed, the property used or contributed and the risks assumed, in respect of the transaction, by the participants in the transaction, (v) 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, in respect of the transaction, and (vi) the assumptions, strategies and policies, if any, that influenced the determination of the transfer prices or the allocations of profits or losses or contributions to costs, as the case may be, in respect of the transaction;.... ...

Under the existing rules, the upstream loan would not be considered to be repaid for the purpose of subsection 90(14). ... Our preference is to be able to do a considered, full analysis in this kind of situation rather than responding incrementally. ... I think you will find that each of Luxco and UKCo, as the intended borrowers, would be considered to have received a loan from Canco of $50, which gives the result there is a deemed shareholder loan of $100, yet Canco only put $50 into the pool. ...

In the case where the Trust is not able to pay the balance of $25,000 of taxable income in the course of the year, we are of the view that this balance will not be considered to be payable by virtue of subsection 104(24). 9 October 2015 APFF Financial Strategies and Instruments Roundtable Q. 6, 2015-0595851C6 F Q.7 Processing delays for charity registrations (a) Is there a different registration process for a charitable organization and a foundation? ... The definition of “eligible offset amount” in subsection 108(1) (the “Definition”) encompasses the portion of any debt or obligation which is assumed by the taxpayer in respect of all or part of the taxpayer’s capital interest in a trust, and that can reasonably be considered to be applicable to property distributed in satisfaction of the interest, if the distribution is conditional upon the assumption by the taxpayer of the portion of the debt or obligation. ...

We are returning to the concept of the VDP as an application – not a submission that will merely be processed by a processing centre as submitted, but something that will get a bit of analysis upfront that will be considered on its facts. ... While CRA will engage in preliminary discussions on a no-name basis, the taxpayer is not considered protected until their identity is revealed. ... Was that a practice that the CRA considered in the policies? Response Ted Gallivan: This is an oversimplification, but I think the government of Quebec still looks at voluntary disclosures as a revenue-leader whereas we are looking at the VDP as a behaviour-influencer. ...

The review also considered the effectiveness of the pre-rulings consultation service, which has been in place since 2013. ... Most countries we considered have a system, similar to ours, that is discretionary and administrative. ... There is currently no link between that stated requirement, and whether the same or substantially similar transactions are being considered by a tax services office or for transactions under audit. ...

CEWS and TPM-17 Rheault: Has CRA considered its position in IFA 2020 Q.5, in light of the OECD’s differing views? ... Therefore, that wording is usually used in situations where we were seriously considering whether a s. 247(3) penalty would apply, but considered that the information before the Committee was insufficient. That is not to say that the penalty would not be considered in the future in a similar situation. ...