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Normally, it is considered reasonable to assume that the profit element in any amount due is that proportion of such amount that the gross profit on the sale bears to the gross selling price; thus a reserve might be allowed equal to the full amount of the profit if no part of the selling price had been received. ... A claim for a reserve equal to the lesser of the gross profit on the sale and the amount due will not be allowed as it is not considered reasonable to assume that the vendor receives no profit until after the full investment in the property sold has been recovered. 13. ...

The motion for an extension of time will be considered together with the leave application. The SCC normally addresses questions of legal interpretation but in certain situations, questions of fact may also be considered. ...

To be considered a major addition, the addition must change the character of the previous complex to such a fundamental extent that the original building and the addition together essentially form a newly constructed residential complex. ... For example, if the renovation of a unit is sufficiently extensive to be considered a “substantial renovation”, the GST/HST new housing rebate will be available either to the qualifying purchaser of such a home from the “builder” or to a qualified individual if the individual carried out the renovation for his or her use as a primary place of residence or engaged a contractor to do the renovation. ...

Amalgamated corporations and subsidiaries that are merged into their parent corporation are also considered predecessor employers for purposes of the Act. ... Other apportionment methods that may also be reasonable, depending on the circumstances of the plan, will be considered on a case-by-case basis. ...

Where an unincorporated organization is separated into a number of branches or divisions, each of these branches or divisions could, if they are sufficiently autonomous, be considered separate persons for GST/HST purposes, and therefore, except for those that are small suppliers, each would be required to register for the GST/HST. ... A branch or division may be considered a person if: the branch or division may sue and be sued in its own name; the branch or division is capable of holding property in its own name; the parent body is not liable for the debts and obligations of the branch or division, and the branch or division is not liable for the debts and obligations of the parent body or of any other branch or division; the branch or division has the capacity to contract in its own name; the branch or division has its own constitution (or charter) and by-laws; the branch or division has its own board of directors and does not have, to any significant extent, directors, officers or employees that are common with the parent body or any other branch or division; the branch or division enjoys a considerable degree of autonomy in its day-to-day operations (e.g., financial resources allocation, program development, staffing, payroll); the branch or division raises most of its revenues as opposed to receiving funding from the parent body (e.g., the branch or division is self-sustaining financially); the accounting activities of the branch or division are separate from those of the parent body and other branches or divisions (e.g., separate books and records, financial statements, bank accounts, etc.); the financial and/or fiscal year of the branch or division is different from the financial and/or fiscal year of the parent body and other branches or divisions; the members of the branch or division are different from the members of the parent body and other branches or divisions; persons do not automatically become members of the parent body or of another branch or division by becoming members of the branch or division and vice versa; and the branch or division has its own distinct seal. ...

" Act " means the Excise Tax Act; " associated persons " persons are considered to be associated in the following circumstances: (a) a particular corporation is associated with another corporation if, by reason of subsections 256(1) to (6) of the Income Tax Act, the particular corporation is associated with the other corporation for the purposes of that Act; (b) a person other than a corporation is associated with a particular corporation if the particular corporation is controlled by the person or by a group of persons of which the person is a member and each of whom is associated with each of the others; (c) a person is associated with: (i) a partnership if the total of the shares of the profits of the partnership to which the person and all other persons who are associated with the person are entitled is more than half of the total profits of the partnership, or would be more than half of the total profits of the partnership if it had profits; and (ii) a trust if the total of the values of the interests in the trust of the person and all other persons who are associated with the person is more than half of the total value of all interests in the trust; and (d) a person is associated with another person if each of them is associated with the same third person; " calendar quarter " means a period of three months beginning on the first day of January, April, July or October in each calendar year; " Departmen t" means the Department of National Revenue, Customs and Excise; " fiscal month " of a person means a period that is determined under section 243 of the Excise Tax Act to be the fiscal month of the person; " fiscal quarter " of a person means a period that is determined under section 243 of the Excise Tax Act to be the fiscal quarter of the person; " fiscal year " of a person means (a) where the person has made an election under section 244 of the Excise Tax Act that is in effect, the period that the person elected to be the fiscal year of the person, and (b) in all other cases, the taxation year of the person; " Minister " means the Minister of National Revenue; " person " means an individual, partnership, corporation, trust or estate, or a body that is a society, union, club, association, commission or other organization of any kind; " prescribed " means (a) in the case of a form, the information to be given on a form or the manner of filing a form, prescribed by the Minister, and (b) in any other case, prescribed by regulation or determined in accordance with rules prescribed by regulation; " registrant " means a person who is registered, or who is required to apply to be registered, under sections 240 and 241 of the Excise Tax Act; " reporting period " of a person means the reporting period of the person as determined under sections 245 to 251 of the Excise Tax Act; " taxation year " of a person means (a) where the person is a taxpayer within the meaning of that term in the Income Tax Act, the taxation year of the person for the purposes of that Act, and (b) in any other case, the period that would be the taxation year of the person for the purposes of that Act if the person were a corporation. ... Pursuant to subsection 280(4) of the Act, penalty and interest payable in respect of instalments not paid by the due date of the net tax on account of which the instalment was payable will be considered to be an amount of net tax not remitted and will, therefore, continue to be subject to penalty and interest until paid. 23. ...

If an incidental seller is considered to be arranging for an exempt supply of insurance by an insurer, the supply of this service by the incidental seller to the insurer will generally be an exempt supply of a financial service. ... Where the essential character of the service for which an incidental seller earns its fees is the sale of insurance on behalf of the insurer to the customer, it will generally be considered an exempt supply of a financial service. ...

The validity of the tax earned by audit measure and its effect on audit decision making was also considered. ... As well, challenges to obtaining necessary documentation and information and recourse processes were considered as were the means to address them, including the use of the inquiry mechanism, which can also be used for civil matters. ...

Programs* 3 3 0 100 Total 83 72 11 87 * All program branches share accountability for these commitments- Appeals, ACB, Customs, and PPB Legend: Appeals- Appeals Branch ACB- Assessment and Collections Branch ITB- Information Technology Branch FAB- Finance and Administration Branch HRB- Human Resources Branch PPB- Policy and Planning Branch CAEB- Corporate Audit and Evaluation Branch Appendix 3: Status of 2001-2004 action plan commitments Goal 1: Prepare managers to contribute to SD Items Descriptions Completed In progress Not started Dropped 1.1 Objective: Demonstrate leadership and commitment to SD 1.1.1 Recognize SD as a corporate value X 1.1.2 Finalize the SD policy X 1.1.3 Fully integrate SD into the business planning and reporting process to support the horizontal nature of SD X 1.1.4 Link our commitment to SD with appropriate messages in the CCRA Leadership Program X 1.2 Objective: Increase practice of balanced decision-making related to programs, policies, and operations 1.2.1 Develop and implement guidelines for integrating SD into the development of business plans and proposals to ensure that all aspects of SD are considered X 1.3 Objective: Raise the level of SD awareness; increase SD skills and knowledge 1.3.1 Develop/implement a SD learning strategy for management X 1.3.2 Review ongoing learning programs to identify SD awareness/training opportunities X 1.3.3 Provide managers with guidance material to support environmental stewardship and compliance X 1.4 Objective: Measure, monitor, and promote continuous improvement for SD results 1.4.1 Integrate SD considerations into key corporate management tools: 1.4.1.1 balanced scorecard 1.4.1.2 risk management policy 1.4.1.3 quality service initiative X 1.4.2 Perform periodic reviews of SDS implementation and report findings to senior management in conjunction with regular audit program X 1.4.3 Conduct a management review of the SDS 2001- 2004 and update the SDS for 2004-2007 X 1.4.4 Close significant gaps in the management and control system for the SDS in particular, documenting procedures and implementing a process for non-conformance and corrective action X Goal 2: Enable employees to contribute to SD Items Descriptions Completed In progress Not started Dropped 2.1 Objective: demonstrate leadership and commitment to SD 2.1.1 Create opportunities for employees to pledge commitment to SD X 2.2 Objective: Raise the level of SD awareness; increase SD skills and knowledge 2.2.1 Create and maintain opportunity for employees to share SD success stories, initiatives, and comments X 2.2.2 Provide employees with guidance material to help support environmental stewardship initiatives X 2.2.3 Encourage participation in CRA-endorsed initiatives, such as the annual commuter challenge (ongoing) X Goal 3: Green operations to contribute to SD Items Descriptions Completed In progress Not started Dropped 3.1 Objective: Demonstrate leadership and commitment to SD by continuing to develop and implement an environmental management system consistent with the ISO 14001 standard 3.1.1 Finalize CRA Environmental Policy X 3.1.2 Develop environmental management programs for all identified environment aspects: Procurement Paper Solid waste management Land use management Energy Water quality and conservation Fleet Ozone depleting substances X 3.1.3 Fully implement all elements of a performance measurement framework for: 3.1.3.1 Storage tanks 3.1.3.2 ODS management X 3.2 Objective: Increase practice of integrated decision-making related to programs, policies, and operations 3.2.1 Develop and pilot the use of SD guidelines for integrating SD into the development of operational resource proposals to ensure all aspects of SD are considered X 3.3 Objective: Measure, monitor, and promote continuous improvement 3.3.1 Develop/refine appropriate administrative systems to track performance on environmental and SD commitments X 3.4 Objective: Enhance or develop new partnerships to support shared SD objectives 3.4.1 Continue participation in interdepartmental committees, working groups and initiatives related to the environment and SD (ongoing) X 3.5 Objective: Meet or exceed federal environmental legislation and regulations and implement best management practices for environmental issues: 3.5.1 Procurement 3.5.1.1 Review/assess current Material Management Certification courses for green content X 3.5.1.2 Pilot green procurement training program with Headquarters' procurement officers; share results of pilot with others X 3.5.1.3 Introduce environmental specifications into National Individual Standing Offers X 3.5.1.4 Increase the number of clauses that give consideration to SD-green procurement into the contractual process, including selection criteria for Requests for Proposals (RFPs) X 3.5.2 Paper 3.5.2.1 Develop/revise procedures and standards to help reduce dependence on paper in internal operations: 3.5.2.1.1 Issue electronic document management standards X 3.5.2.1.2 Increase availability of forms, policies, and procedures on the Intranet (ongoing) X 3.5.2.1.3 Enhance and administer the protocol for submissions to the Agency Management Committee and Board of Management to help reduce paper use X 3.5.2.1.4 Implement an initiative to submit documents electronically to the National Archives/National Library X 3.5.3 Waste management 3.5.3.1 Divert an average of 50% solid waste from landfill in priority custodial facilities X 3.5.3.2 Implement best management practices for waste management including recycling at remaining custodial facilities X 3.5.3.3 Divert an average of 70% solid waste from landfill in priority leased facilities X 3.5.3.4 Integrate the requirement for contractor to provide waste reduction plans into all major construction, renovation and demolition projects in custodial and leased facilities (carry-over commitment) X 3.5.3.5 Implement best practices and initiatives related to the disposal (recycling/reusing) of obsolete or surplus goods: 3.5.3.5.1 Develop national disposal guidelines for publications no longer required 3.5.3.5.2 Review existing disposal guidelines for opportunities to integrate SD considerations 3.5.3.5.3 Assess/implement surplus uniform donations program X 3.5.4 Energy 3.5.4.1 Develop and communicate best management practices for energy efficiency X 3.5.4.2 Continue to participate in federal climate change initiatives (to be done in conjunction with the federal climate change initiative) X 3.5.4.3 Negotiate the inclusion of energy efficiency measures at leased facilities X 3.5.4.4 Implement energy and water conservation measures associated with the Federal Buildings Initiative (or other programs) when an energy assessment has demonstrated that it is cost-effective X 3.5.4.5 Incorporate energy efficiency measures, including the use of renewable energy alternatives, into major construction and renovation projects where feasible and cost effective with life-cycle payback X 3.5.5 Land use management Compliance assurance related to CEAA 3.5.5.1 Strengthen protocol to monitor/report on follow-up activities recommended by environmental assessment screening reports X Capital construction/renovation 3.5.5.2 Implement measures to "green" new capital construction projects (ongoing) X Compliance assurance with the Canadian Environmental Protection Act (CEPA): Storage tank regulation 3.5.5.3 Strengthen protocol to demonstrate compliance with CEPA's Federal Storage Tanks Regulation X Compliance with federal policy on contaminated sites 3.5.5.4 Strengthen protocol to demonstrate compliance with the federal policies for contaminated sites X 3.5.5.5 Assess and remediate contaminated sites consistent with best practices (ongoing) X 3.5.6 Ozone depleting substances (ODS) management 3.5.6.1 Manage inventories to reduce releases of ODS consistent with the Federal Halocarbon Regulations X 3.5.6.2 Implement management plan to convert / replace ODS inventories with alternative substances or technologies X 3.5.7 Fleet management 3.5.7.1 Reduce fleet emissions by increasing the number of alternative fuel vehicles in compliance with the Alternative Transportation Fuels Act (ATF) X 3.5.7.2 Continue reporting on compliance with the Alternative Fuels Act (annually) X 3.5.7.3 Co-ordinate fleet awareness training as opportunities arise through the government initiatives on climate change X 3.5.8 Water management 3.5.8.1 Strengthen protocol for water quality management X 3.5.8.2 Develop and communicate best management practices for water conservation X 3.5.8.3 Incorporate water conservation measures into major construction and renovation projects where feasible X 3.5.9 Hazardous substances management 3.5.9.1 Review hazardous materials management X 3.5.9.2 Develop strategies and action plans as required X 3.5.9.3 Strengthen protocol for Workplace Hazardous Materials Information System (WHMIS) X 3.5.10 Environmental emergencies 3.5.10.1 Strengthen protocol for environmental emergencies X Goal 4: Enhance programs to contribute to SD Items Descriptions Completed In progress Not started Dropped 4.1 Objective: Demonstrate leadership and commitment to SD 4.1.1 Explore ways to communicate our commitment to SD to clients, partners, and stakeholders and encourage their support X 4.1.2 Implement specific initiatives that help encourage compliance with Canadian laws, protect the health and safety of Canadians, and promote eco-efficiency: 4.1.2.1 Administrative Monetary Penalty System (AMPS) 4.1.2.2 Migrant health program 4.1.2.3 Pre-approval permit programs X 4.2 Objective: Increase practice of integrated decision-making related to programs, policies, and operations 4.2.1 Integrate SD into program management tools and practices: 4.2.1.1 negotiate inclusion of SD considerations in the Service Management Framework arrangements with provinces and territories to articulate CRA's commitment to SD 4.2.1.2 Incorporate SD in the CRA Business Development Strategy 4.2.1.3 Integrate environmental considerations into the Customs Self-Assessment initiative to reduce waiting times, trucks idling at borders X 4.2.2 Integrate consideration of SD into development of new program proposals and initiatives X 4.3 Objective: Measure, monitor, and promote continuous improvement 4.3.1 Explore ways to measure and report performance results of programs on all three aspects of SD X 4.4 Objective: Enhance or develop new partnerships to support shared SD objectives 4.4.1 Incorporate SD considerations into consultations with partners: 4.4.1.1.1 E-commerce conference 4.4.1.1.2 Memoranda of Understanding (MOU) with partners 4.4.1.1.3 Voluntary Sector Joint Initiative Action Plan 4.4.1.1.4 Annual consultation process X 4.4.2 Continue to work with other government departments in support of sustainable development: 4.4.2.1 Identify health and safety issues for trade and border compliance plan X 4.4.2.2 Harmonize customs procedures and electronic systems in support of Asia Pacific Economic Cooperation and Free Trade Area of the Americas trade facilitation initiatives X 4.5 Objective: Implement best management practices for environmental issues in program delivery: paper consumption procurement waste 4.5.1 Advance the use of electronic service delivery options and streamline paper-based transactions with the aim of reducing the use of paper: 4.5.1.1 Implement electronic service delivery options (ongoing) X 4.5.1.2 Implement the Correspondence Issue Management System (due March 31, 2005) X 4.5.1.3 Play lead role in global e-commerce industry by promoting e-filing and telefiling X 4.5.1.4 Negotiating the filing of RRSP listing to reduce need for paper filing X 4.5.1.5 Develop e-filing of objections through the Internet X 4.5.1.6 Develop Web-based training on blueprint initiatives X 4.5.2.7 Review forms and publications and expand use of Web site for distribution of information to clients X 4.5.1.8 Convert archival information onto software X 4.5.1.9 Reduce paper in charities tax package (T3010) by approximately 33% X Appendix 4: List of abbreviations AMPS Administrative Monetary Penalty System ACB Assessment and Collections Branch APEC Asian- Pacific Economic Coorperation AWICS Agency-wide Classification System BFTSO Burnaby-Fraser Tax Services Office Appeals Appeals Branch CAEB Corporate Audit and Evaluation Branch CAS Corporate Administration System CBSA Canada Border Services Agency CEAA Canadian Environmental Assessment Agency CEW Canadian Environment Week CIDA Canadian International Development Agency CIMS Correspondence Issue Management System CPB Corporate Business Plan CPE Customs Port of Entry EDM Electronic Document Management EMP Environmental Management Program EMS Environmental Management System EPPD Executive Personnel Programs Directorate ESS Employer Self-Service FAB Finance and Administration Branch FAST Free and Secure Trade FIHO Federal House In Order Initiative FPSCD Financial Policy Systems and Control Division HRB Human Resources Branch IMD Information Management Directorate MMD Materiel Management Directorate MSDS Material Safety Data Sheets MSS Manager Self-Service ITB Information Technology Branch OECD Organisation for Economic Co-operation and Development OPI Office of Primary Interest PATA Pacific Association of Tax Administrations PPB Policy and Planning Branch PWGSC Public Works and Government Services Canada PWRA Potable Water Risk Assessment RARD Revenue Accounting and Reporting Division SD Sustainable development SDS Sustainable development strategy SDGO Sustainable Development Government Operations SIMA Special Import Measures Act SMF Service management framework TPSD Telecommunications and Program Support Directorate TC Tax centre TSO Tax services office VSI Voluntary Sector Initiative WHMIS Workplace Hazardous Materials Information Systems WCO World Customs Organization Previous page Page details 2017-06-22 ...

(Prior to May 23, 1985 loans that were not considered genuine (see IT-260R) were treated as transfers but this distinction is no longer necessary.) ... Where depreciable property is transferred to a related minor and the minor has other property of the same class as the property transferred, in computing the income or loss from the property attributed to the transferor (a) a reasonable portion of the capital cost allowance claimed by the minor in respect of the class (which portion may not exceed the maximum capital cost allowance that would be deductible in respect of the transferred property if the property were in a separate class) may be deducted, and (b) a terminal loss or recapture of capital cost allowance which arises and would otherwise be included in computing the income of the minor in respect of the class of depreciable property should be taken into account to the extent that such amount can reasonably be considered to relate to the transferred property. ...