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Furthermore, the reporting entity would report their share of income and/or gains/losses with respect to specified foreign property on Form T1135, based on their ownership interest in the underlying property and without consideration given to the attribution rules. ...

Position: Provided information Reasons: It is a factual determination that is made after giving consideration to the terms of the plan and the circumstances in which it is to be implemented. ...

Note that proposed amendments to the Act will allow the transfer of property to a qualified donee to be recognized as a gift, for tax purposes, in certain circumstances where a donor has received consideration for property transferred after December 20, 2002. ...

However, we want to undertake a thorough study, by taking into consideration, among others, the extent of the problem before determining which approach to adopt in such a situation. ...

Such a determination would require full consideration of the unique facts in a given situation. ...

Ainsi, pour le calcul de la surtaxe, il faut prendre en considération le crédit fédéral d'impôt pour opérations forestières. ...

The deductible amount of interest should generally be determined by using the same proportion, determined on a reasonable basis, that the work space (i.e. the current eligible income-earning use) is of the principal residence and taking into consideration the personal use, if any, of the work space. ...

Her Majesty the Queen, 2002 DTC 7442, the Federal Court of Appeal held that the qualifying period requirement can be met where the work done in the period relates to more than one contract of the employer as long as the employee was employed throughout the entire qualifying period under consideration and each of the contracts otherwise met the requirements for the OETC. ...

Generally, a plan will be considered to be a superannuation or pension plan where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodic payment on or after the employee's retirement. ...

In other words, consideration is given to whether the PCs and the professionals are providing services as independent contractors and the reasons that may exist for providing the services through the PCs. ...