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However, if the taxpayer's legal representative applies in writing within that period to the Director of the local Revenue Canada tax services office, an extension of the period to what is considered reasonable in the circumstances may be granted. ¶ 5. ... If a gift is described in two or more of the categories of "total charitable gifts," "total Crown gifts," "total cultural gifts" or "total ecological gifts" made after February 27, 1995, it will be considered in the following order: a cultural gift, an ecological gift, a Crown gift, and a charitable gift. ¶ 8. ... The reader should, therefore, consider such comments in light of the relevant provisions of the law in force for the particular taxation year being considered, taking into account the effect of any relevant amendments to those provisions or relevant court decisions occurring after the date on which the comments were made. ...

The intention of the person enrolling in the course is not considered by the Department in determining whether a course relates to a trade or vocation. (3) Attest to the Competence of Individuals to Practice or Perform a Trade or Vocation Section 8 requires the certificate, diploma, licence or similar document issued by an educational institution to "attest to the competence of individuals" to practice a trade or vocation. ... (a) Courses That Are Part of a Full-time Program An individual course is considered by the Department to attest to the competence of individuals to practise or perform a trade or vocation if: (i) The course is offered as a credit in a full-time program that is offered by the same institution; and (ii) The full-time program is offered on a pass/fail basis, based on the evaluation of the student's performance on a single, or series of, tests, graded materials or projects. ... Factors considered by the Department in determining whether a program of courses represents a 'full-time' program include the length of the program, the cost of the program and the curriculum and description of the program and its courses, as noted in the school's promotional material (e.g., brochures, advertisements, literature, course calendars, syllabi and telephone listings). ...

Decision Research activities that are related to care provided to inpatients and outpatients of a public hospital are considered to be activities engaged in by a hospital authority in the course of operating a public hospital. ... Examples of research activities that are, and are not, considered to be related to patient care for purposes of the public service body rebate can be found under the heading "Research and activities of operating a public hospital". ... A facility that does not have all the above characteristics is not considered to be a public hospital for purposes of the definition of hospital authority and the entitlement to the 83% rebate of the GST and federal part of the HST and corresponding rebate of the provincial part of the HST for tax incurred in activities of operating a public hospital. ...

It does not prevent the Minister from assessing or auditing the taxpayer for other taxation years, and/or for other issues not considered under the audit agreement. ... The relevant International Advisory Services Section Manager of the International Tax Division must be consulted in all cases where an audit agreement is being considered for a transfer pricing issue. ... To help ensure that the taxpayer fully understands all the facts and the consequences related to both the audit agreement and the waiver, there must be a meeting with the taxpayer and any representative to discuss the following topics: rationale for the method to be used to assess each issue being resolved and the applicable ITA/ETA sections taxation years pertinent to each issue degree to which the taxpayer understands the rationale for the assessment of each issue being resolved taxpayer's rights of objection and appeal prior to waiving objection rights and the fact that objection and appeal rights will not be available after signing the waiver taxpayer's right to seek independent legal advice financial impact of waiving objection rights for each issue, without interest calculation; explanation that the agreement does not establish any general or administrative precedent applicable to any other taxpayers understanding that the agreement depends on the specific facts disclosed and that the CRA may consider the agreement invalid if significant and material new information comes to the attention of the CRA the audit agreement is considered binding upon the taxpayer and their legal representative (where applicable) provided the taxpayer: signs and returns the waiver document and it has been signed freely and without duress; fully disclosed all material facts in its returns (e.g., T1, T2, T3, etc.), elections and applications; and fully disclosed all material facts related to the issues dealt with in the audit agreement. ...

Collection of tax Prior to February 5, 2022, where a person performs a mining activity of validating transactions and adding them to a publicly distributed ledger as a solo miner that is engaged in a commercial activity, the provision of those activities would be considered a taxable supply for GST/HST purposes. ... Each particular person within the pool or group is considered to perform these mining activities in a similar fashion as a solo miner. ... The requirements to self-assess tax under Divisions IV and IV.1, as set out previously for solo miners, may also need to be considered. ...