Search - consideration

Some common areas for consideration are listed below: Income Any foreign income you report has to be shown in Canadian dollars on your Canadian income tax return (this also applies to deductions claimed). ... Tuition, education, and textbook amounts In choosing a foreign educational institution, an important consideration is whether you will be able to claim the tuition fees you paid and the related education and textbook amounts. ...

The subsection 148.1(1) definition of "eligible funeral arrangement" provides that the following payments (other than any portion of those payments that are contributed to a cemetery care trust-- see ¶ 5(c) above) are considered to be made under a separate arrangement that is not an EFA: (a) any payment made as consideration for the immediate acquisition of a right to burial in or on property that is set apart or used as a place for the burial of human remains; or (b) any payment made as consideration for the immediate acquisition of any interest in a building or structure for the permanent placement of human remains. ...

More information on these considerations is available in Brochure RC4106. ... The draft policy takes into consideration the many goals and undertakings of ethnocultural organizations in Canada, and outlines how organizations that help a disadvantaged ethnocultural community or communities are potentially eligible for charitable registration. ...

The following special rules apply to a revoked plan: the revoked plan is deemed not to be a DPSP, an employee profit sharing plan, or a retirement compensation arrangement; the revoked plan cannot be accepted for registration or be deemed to have become registered under subsection 147(5) of the Act until at least one year after the effective date of revocation; the trust is taxable on its taxable income for a taxation year if the trust was governed by a revoked plan for any part of that year; the employer cannot deduct from its income payments made to a trustee under the plan at a time when the plan is a revoked plan; any amount received by a beneficiary under the plan will be included in the beneficiary's income to the extent it would have been included in income under subsection 147(10) of the Act if the plan had been a deferred profit sharing plan; the value of any funds or property appropriated to or for the benefit of a taxpayer who is an employer making payments to the plan, or a corporation with which such an employer does not deal at arm's length, to the extent it would have been included in income under subsection 147(13) of the Act if the plan had been a deferred profit sharing plan (see 42 below); and if property of a revoked plan is disposed of to, or is acquired from, a taxpayer for a consideration other than the fair market value of the property at the time of the transaction, the difference between the consideration and the fair market value will be taxable, as provided in 45 below. ...

Response 6 We are presently monitoring the number and types of rectification applications and orders and will receive further guidance from the courts on the cases that are presently under consideration and, based on that, will determine if a legislative amendment is desirable. ... Consideration will be given as to whether there is an agency or employer-employee relationship in situations where it is determined that the taxpayer does not have sufficient physical control of the work space to establish a fixed base/permanent establishment. ...

This additional allocation is based on what is reasonable in the circumstances, taking into consideration the investment in the partnership, including the debt obligations of the partnership, of each such member of the partnership. ... The allocation is based on what is reasonable in the circumstances, taking into consideration each non-specified member's investment in the partnership, including debts of the partnership. ...

Response 6 We are presently monitoring the number and types of rectification applications and orders and will receive further guidance from the courts on the cases that are presently under consideration and, based on that, will determine if a legislative amendment is desirable. ... Consideration will be given as to whether there is an agency or employer-employee relationship in situations where it is determined that the taxpayer does not have sufficient physical control of the work space to establish a fixed base/permanent establishment. ...

The subsection 148.1(1) definition of "eligible funeral arrangement" provides that the following payments (other than any portion of those payments that are contributed to a cemetery care trust-- see ¶ 5(c) above) are considered to be made under a separate arrangement that is not an EFA: (a) any payment made as consideration for the immediate acquisition of a right to burial in or on property that is set apart or used as a place for the burial of human remains; or (b) any payment made as consideration for the immediate acquisition of any interest in a building or structure for the permanent placement of human remains. ...

Interest, while not defined in the Act, has been described in general terms in the Courts as "the return or consideration or compensation for the use or retention by one person of a sum of money, belonging to, in a colloquial sense, or owed to, another". ... Applicable to taxation years commencing after 1982, where a taxpayer has accrued and reported interest income on a debt obligation and has at any particular time disposed of the obligation for consideration equal to its fair market value at the time of disposition, the taxpayer may, by virtue of subsection 20(21), deduct in computing income for the year of disposition, the amount, if any, by which the aggregate of the amounts of interest from that debt obligation that was included in the taxpayer's income for the year of disposition and all previous years exceeds the total interest actually received thereon. ...

The following special rules apply to a revoked plan: the revoked plan is deemed not to be a DPSP, an employee profit sharing plan, or a retirement compensation arrangement; the revoked plan cannot be accepted for registration or be deemed to have become registered under subsection 147(5) of the Act until at least one year after the effective date of revocation; the trust is taxable on its taxable income for a taxation year if the trust was governed by a revoked plan for any part of that year; the employer cannot deduct from its income payments made to a trustee under the plan at a time when the plan is a revoked plan; any amount received by a beneficiary under the plan will be included in the beneficiary's income to the extent it would have been included in income under subsection 147(10) of the Act if the plan had been a deferred profit sharing plan; the value of any funds or property appropriated to or for the benefit of a taxpayer who is an employer making payments to the plan, or a corporation with which such an employer does not deal at arm's length, to the extent it would have been included in income under subsection 147(13) of the Act if the plan had been a deferred profit sharing plan (see 42 below); and if property of a revoked plan is disposed of to, or is acquired from, a taxpayer for a consideration other than the fair market value of the property at the time of the transaction, the difference between the consideration and the fair market value will be taxable, as provided in 45 below. ...