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Technical Interpretation - External

3 May 2010 External T.I. 2010-0361631E5 - Calculation of Indian exempt income

Such time is not considered to be work time related to a specific location on or off a reserve and therefore should not be taken into consideration in establishing the percentage of employment duties performed on a reserve. ...
Technical Interpretation - External

16 November 2010 External T.I. 2010-0379101E5 - Work Space in the Home

Note however, that in order to be reasonable, the calculation should also take into consideration any personal use of the work space. ...
Technical Interpretation - External

25 July 2016 External T.I. 2016-0630781E5 - 104(13.3) and a CPP/QPP death benefit

For example, one consideration is the “executor’s year”. The following was stated, in part, in the 2011 STEP CRA Roundtable- Question 4 (our document 2011-0401851C6): Paragraph 6 of Interpretation Bulletin IT-286R2, “Trusts- Amount Payable”, discusses the notion of the “executor year” under common law for a testamentary trust. ...
Technical Interpretation - Internal

10 May 2016 Internal T.I. 2016-0644761I7 - RPP borrowing

In this case, consideration should be given to requiring any excess investment earnings to be withdrawn from the Plan. ...
Conference

29 November 2016 CTF Roundtable Q. 12, 2016-0669851C6 - Support for US FTC Claims

The CRA will take your suggestion under consideration. CRA Response (b) The Canadian FTC is dependent on a confirmed final tax liability with the foreign tax authority and the supporting documents requested are proof of that confirmed final tax liability. ...
Conference

29 November 2016 CTF Roundtable Q. 8, 2016-0671501C6 - 55(2) clause 55(2.1)(b)(ii)(B)

For example, if a corporate shareholder transfers a property it owns (other than shares of the corporation) to the corporation or to another person, a taxable gain will be realized if the cost amount of the consideration received on the transfer is greater than the cost amount of the property transferred. ...
Technical Interpretation - Internal

24 January 2017 Internal T.I. 2016-0675902I7 - Canadian exploration expense

As noted when the original Guidelines were drafted, the Canada Revenue Agency’s consideration of this issue has been limited to an overall review of general principles. ...
Technical Interpretation - External

19 September 2007 External T.I. 2007-0252761E5 - Canadian exploration expense

Consequently, our consideration of this issue has been limited to an overall review of general principles. ...
Conference

2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.1, 2016-0674221C6 F - General deduction from tax - 123.4

., c’est la moins élevée des sommes déterminées à l’égard de la société pour l'année selon les alinéas 125(1)a) à c) L.I.R. qui est prise en considération. ...
Technical Interpretation - External

20 March 2017 External T.I. 2014-0545591E5 - Upstream Loan and Debt Forgiveness Rules

Canco sells all of its interest in FA to a third party for fair market value consideration. ...

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