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Administrative Policy summary

GST/HST Memorandum 20-5 “School Cafeterias, University and Public College Meal Plans, and Food Service Providers” December 2019 -- summary under Section 13

Cards issued by a university or public college to students for a qualifying meal plan are not considered to be gift cards.... ...
Administrative Policy summary

FAQ - Deferral of GST/HST Tax Remittances: CRA and COVID-19 20 April 2020 CRA Webpage (as amended on June 29, 2020) -- summary under Subsection 281.1(1)

Q.11 Consideration of late-filed rebate claims GST/HST rebates that are late filed may be considered for processing. ...
Administrative Policy summary

GI-197 “Out-of-Pocket Expenses” 17 December 2021 -- summary under Supply

Typical out-of-pocket expenses not generally incurred as agent that a registered supplier may charge a client include …: office supplies, if they are associated with the service being performed by the supplier for the client air travel local transportation, such as a taxi parking hotel or other accommodation per diem amounts, such as meals car rentals and gasoline an automobile allowance, where the supplier’s personal vehicle is used in the performance of the service Expenses incurred as agent When a supplier incurs an out-of-pocket expense as a client’s agent … the client is considered to be the recipient of the supply. ...
Administrative Policy summary

Notice to Tax Professionals: Updates to filing process for a pertinent loan or indebtedness election, 25 March 2022 -- summary under Subsection 15(2.11)

Required information in the election The CRA is expanding the amount of information a taxpayer must provide with their election in order for it to be considered valid. … New information requested includes: Identification of the first taxation year in respect of which this PLOI election is to be made, the total amount owing initially and the currency in which it is denominated. ...
Administrative Policy summary

25 March 2021 CBA Commodity Taxes Roundtable, Q.19 -- summary under Subsection 206(2)

CRA responded: While a change in use of 10% or more is normally considered to be a significant change in use (i.e. because section 197 considers any change of less than 10% to be insignificant), section 141 nevertheless considers that the entire use of the capital property is not commercial activities. ...
Administrative Policy summary

Underused Housing Tax Notice UHTN8 Special Rule and Elections for Individual Owners of Multiple Residential Properties February 2023 -- summary under Subsection 6(10)

However, it is possible that your (or your spouse’s or common-law partner’s) personal occupancy of a dwelling unit may still be considered for the exemption for qualifying occupancy (that is, for Type 2 qualifying occupants). ...
Administrative Policy summary

Mandatory disclosure rules – Guidance, 15 August 2024 CRA Webpage -- summary under Contractual Protection

Examples include tax indemnities in standard provisions such as gross-up clauses in loan agreements or ISDA agreements, or in employment and severance agreements As another example, an employee of a Canadian bank provides general information to a client regarding the tax benefits of contributing to an RRSP and the RRSP plan document provides that the client will indemnify the trustee (a bank subsidiary) in the event that the RRSP plan is subject to tax, for example, as a result of holding a non-qualified investment: this indemnity “is not considered to be contractual protection in respect of the avoidance transaction, on the basis that this indemnity is a form of protection that applies in the normal commercial or investment context.” ...
Administrative Policy summary

Income Tax Folio S4-F3-C2, Provincial Income Allocation, 30 January 2024 -- summary under Subsection 402(3)

In addition, any amounts that are included in income pursuant to paragraphs 12(1)(a) or (b) would also be considered gross revenue for purposes of Part IV of the Regulations. ...
Administrative Policy summary

Matias Milet, "FATCA and Canadian Investment Entities," Journal of International Taxation, March 2015, p. 29. -- summary under (j)

Authorized sub-advisor to a non-authorized fund manager (p. 35) …[W]ould a portfolio manager, subadvisor, or administrator that has a contractual relationship with the "primary" fund manager be considered to be managing the entity in determining if paragraph, (k) is satisfied? ...
Administrative Policy summary

25 February 2016 CBA Roundtable, Q. 4 -- summary under Subsection 317(3)

However, exceptions would be considered in some circumstances to proceed with administrative garnishment action at a rate that would exceed the provincial limitations. ...

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