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A trust will not be considered an alter ego trust if it so elects in its T3 return for its first tax year. ... Related persons are not considered to deal with each other at arm’s length. ... Payment for unused sick leave is considered a death benefit and is income of the estate or beneficiary who receives it. ...

. ¶2.5 (formerly included in ¶3 of IT-516R2) has been updated at item (a) to clarify what could be considered a college or university for purposes of subparagraph 118.5(1) (a) (i). Item (b) has been updated to clarify the meaning of the term professional organization for purposes of determining whether an organization would be considered an other educational institution pursuant to paragraph 118.5(1) (a). ... The proposed changes of June 26, 1996 formerly noted in ¶8 have been deleted. ¶2.8 (formerly included in ¶ 8 of IT-516R2), now includes a discussion of academic upgrading courses. ¶2.9 (formerly included in ¶ 8 of IT-516R2), has been revised to explain the CRA’s position regarding the meaning of occupation and English or French second language training at an HRSDC-certified institution for the purposes of the tuition tax credit. ¶ 2.10 (formerly included in ¶9 of IT-516R2) has been updated at item (a) to reflect the amendment to subparagraph 118.5(1) (b) (i) amended by 2011, c. 24, s. 29(2), applicable to tuition fees paid for the 2011 and subsequent tax years. ¶ 2.12 (formerly included in ¶10 of IT-516R2) clarifies the meaning of the term university for purposes of determining whether a foreign educational institution would be considered a university pursuant to paragraph 118.5(1) (b). ¶ 2.13 (formerly included in ¶6 of IT-516R2) has been updated to reflect the new address to which enquiries should be sent for consideration as a university outside Canada. ¶2.15 (formerly included in ¶7 of IT-516R2) has been revised to clarify the meaning of commute for purposes of paragraph 118.5(1) (c). ¶2.16 has been added to provide references to other CRA publications relevant to students attending universities outside Canada. ¶2.19 has been added to explain the CRA’s position regarding online attendance for purposes of the requirement for full-time attendance in paragraph 118.5(1) (b). ¶2.20 has been added to explain the CRA’s position regarding correspondence courses for purposes of the requirement for full-time attendance in paragraph 118.5(1) (b). ¶2.22 (formerly included in ¶13 of IT-516R2) has been revised to include the meaning of enrolled for purposes of paragraph 118.5(1) (a) and (c). ¶2.23- 2.25 (formerly included in ¶16 and 17 of IT-516R2) have been amended to clarify whether a student in receipt of a scholarship, fellowship, bursary or prize may claim a tuition tax credit in respect of the student’s tuition. ¶2.26 has been added to address whether a student may claim the tuition tax credit where the student’s tuition fees are paid by the employer of the student’s family member. ¶2.28 has been added to provide an example of when a tuition tax credit would not be available pursuant to subparagraph 118.5(1) (a) (iii.1) or (v). ¶2.29 (formerly included in ¶14 of IT-516R2) now makes reference to the student’s ability to carry forward unused tuition amounts to be used in future years, pursuant to subsection 118.61(1), added by 1998, c. 19, s. 28(1), applicable to the 1997 and subsequent tax years. ¶2.31 (formerly included in ¶24 of IT-516R2) has been updated to reflect the amendment to subparagraph 118.5(1) (b) (i), amended by 2011, c. 24, s. 29(2), applicable to tuition fees paid for the 2011 and subsequent tax years. ¶2.36 and 2.37 have been added further to the introduction of subsection 118.5(3), concerning ancillary fees and charges. ...

In general, the CCRA position is that for prepaid funeral arrangements where the contributions are held in trust pursuant to provincial legislation and/or the terms of the arrangement, the contributions are not considered to be prepayments. ... Additionally, where the income generated by the funds held in trust is payable directly to the funeral home, pursuant to provincial legislation and/or the terms of the arrangement, that income is considered to be part of the consideration for the services to be provided by the funeral home and is subject to the GST/HST at the time that it is paid to the funeral home. ... In vitro diagnostic products are not considered drugs included by name or description, in the schedules to the Food and Drugs Act. ...

These employer contributions to the PRPP are not considered as taxable income to the employee. ... Is the PRPP considered to be a defined contribution or defined benefit vehicle? ... Regardless of the designated beneficiary, the spouse or common law partner of a member who dies is considered, if applicable, as the beneficiary within the meaning of the PRPP. ...

Where a full ITC is not available to the recipient, the transaction will not be considered a wash transaction. ... The waiver of penalty and interest in excess of 4% of the tax not properly charged or the ITCs not properly accounted for in a wash transaction will normally be considered automatically by the CRA during the audit process. ... The waiver of interest in excess of 4% of the tax not properly charged in a wash transaction will normally be considered automatically by the CRA during the audit process. ...

Excluded from the amount determined in 6(a) above, for dispositions occurring after November 12, 1981, is the portion of realized capital gains or losses on property, other than designated property, which can reasonably be considered to have accrued during any period that the property was held by a corporation when it was not a private corporation, an investment corporation, a mortgage investment corporation, or a mutual fund corporation. ... Also excluded from the amount determined in 6(a) above, for dispositions occurring after November 26, 1987, is the portion of the realized capital gains or losses on property, other than designated property, which can reasonably be considered to have accrued during any period that the property or property for which it was substituted, was held by a corporation that was (a) controlled, directly or indirectly in any manner whatever (see subsection 256(5.1)), by one or more non- resident persons and, after November 26, 1987, the property became the property of a Canadian-controlled private corporation, otherwise than as a consequence of the change in residence of one or more shareholders of the corporation, or (b) exempt from tax under Part I of the Act and, after November 26, 1987, the property became the property of a private corporation that was not exempt from tax under Part I. ... Provided that the amount of the dividend that was the subject of the election was repaid in full to the corporation before a date that was stipulated by the Minister the amount would be considered to be a loan to which sections 15 and 80.4 did not apply. ...

The recommendations by the JRT deal with some of the most salient areas of federal charity regulation and will be considered seriously and speedily. ... This will not be considered if a registered charity changed its focus after registration to non-charitable activities, or if the request is solely based on the charity no longer wanting to be registered. ... In the case of consolidations, all original bodies are considered to undergo voluntary revocation. ...

Records or documents prepared in this time period are considered to satisfy the documentation-due date requirement. Pursuant to subsection 247(4), a taxpayer is deemed not to have made reasonable efforts unless the taxpayer makes or obtains, on or before the documentation-due date, 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, in respect of 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, in respect of 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 contributions to costs, as the case may be, in respect of the transaction. ... Examples of some of the items the TPRC will possibly take into consideration during the evaluation are: whether the documents obtained or prepared by the taxpayer contain a description that is complete and accurate in all material respects of the items listed in 247(4); whether the documents were prepared or obtained by the documentation-due date; and whether the documents were provided within three months of a written request to do so; where a foreign-based requirement under section 231.6 of the Act, and/or any domestic-based requirement under section 231.2 was issued, whether the taxpayer provided all of the items requested; the significance of the controlled transactions subject to penalty consideration in terms of the taxpayer's overall business and whether the documentation prepared or obtained by the taxpayer was sufficient given the significance of the transaction; what efforts have been made to determine and use arm's length transfer prices or allocations, that is, evidence of "reasonable efforts"; the magnitude of the transfer pricing adjustments required; any downward transfer pricing adjustments considered for setoff against upward transfer pricing adjustments in calculating the amount subject to penalty; the auditor's comments on each of the points raised in the taxpayer's representations; and any comments made by the Large File Case Manager. ...

An excise duty return that is mailed on or before the due date of the return, but is not received by the Summerside Tax Centre by the due date, is not considered to be late-filed if the postmark is dated on or before the due date of the return. ... The date of the teller’s stamp will be considered as the date received. ... As per subsection 300(2), a payment of excise duty is considered to be received only when it is in the hands of the Receiver General. ...

The Agency is strengthening its governance over learning through the introduction of new directives and guidelines that will be considered by the Board at its meetings in June. ... Response In 2008-09, the internal mobility rate (including promotions, transfers and lateral moves) was of 21. 6% in the CRA a level considered to be indicative of sound learning and development. ... Key Questions 1: What processes are in place to ensure that the workplace is safe and that employees' health and wellness are being considered? ...