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Technical Interpretation - Internal
6 December 2021 Internal T.I. 2019-0792581I7 - 152(1.1) Notice of Determination
In fact, the Federal Court of Appeal decision for Burnet (footnote 6) supports the view that an ascertainment is a “definite undertaking” by the Minister to take the loss in question “into consideration” for the taxation year and “issue a Notice of Determination accordingly.” ...
Technical Interpretation - Internal
8 September 2022 Internal T.I. 2022-0947811I7 - DTC transfer - meaning of dependent for support
Consideration should be given to whether or not the actions or contributions of the other individual vis-à-vis the PWD or the person with an infirmity (e.g., for the purpose of computing element D of the formula in subsection 118.2(1), or a tax credit under paragraph (d) of element B in the formula under subsection 118(1)) are of such a nature and degree that they could be said to constitute support of the particular individual, and that a relationship of factual dependency can be said to exist, that is, reliance on that support. ...
Technical Interpretation - Internal
31 July 2023 Internal T.I. 2021-0876331I7 - SR&ED ITC Recapture Rules
(footnote 6) Accordingly, in the situation presented, while a question of fact and law, it appears that the trees would be considered the particular property that has been acquired from a person or a partnership (paragraph 127(27)(a) of the Act) or acquired from a transferor (subsection 127(32) of the Act) since the taxpayer will receive property from the province in exchange for the payment of consideration (i.e., the stumpage fees) in accordance with the terms of the timber sales contract entered into between the parties. ...
Technical Interpretation - Internal
2 November 1999 Internal T.I. 9923277 F - PARTICIPATION INDIVISE - TEST POUR 1100(14)
The Court considers the use of the building and in that consideration the percentage of the space that was used by the Appellant. ...
Technical Interpretation - Internal
5 June 1992 Internal T.I. 9129917 F - Banks' Securities Transactions - Income or Capital
Economic considerations dictated the sale in 1951. His Honour held that the profit on sale was made in the carrying on of the company's business and was assessable as a profit according to the ordinary usages and concepts of mankind. ... One important consideration in buying shares was that they should immediately- or within a reasonable period- produce a dividend yield of 4% or better. ...
Technical Interpretation - Internal
3 March 2015 Internal T.I. 2014-0527842I7 - Taxable benefit for an aircraft
In determining the value of benefit, one may take its cost into consideration. ... The judge’s considerations lead us to conclude that a method for valuation of the benefit based on operating costs and CCA can be suitable in various circumstances as long as it is close to the FMV. ... The Yorkton Broadcasting Company Limited (footnote 64) case, upon which the judge in Edward Laurence (footnote 65) based his decisions, is the only Court decision in which the taxpayer invoked the previous version of Bulletin IT-160R3 but for which the judge did not extend any consideration. ...
Technical Interpretation - Internal
11 January 2001 Internal T.I. 2000-0001017 - Sourcing of income & foreign tax credit
A determination of the place where a particular business (or a part thereof) is carried on necessarily depends upon consideration of all the relevant facts, but has been stated in general terms to be the place where the operations in substance take place. ...
Technical Interpretation - Internal
5 July 2012 Internal T.I. 2010-0388551I7 F - Fiducie - retour de sommes
Toutefois, il faudrait prendre en considération qu'elle a déjà été imposée sur les revenus qui lui ont été attribués par Fiducie. ...
Technical Interpretation - Internal
12 December 2014 Internal T.I. 2014-0524751I7 F - Redevances perçues d'avance
Dans la mesure où, dans le calcul de la provision, ces obligations ont été prises en considération, le montant de la provision devrait être réduit. 13 Canderel Ltd. v. ...
Technical Interpretation - Internal
6 February 2015 Internal T.I. 2015-0566681I7 F - Redevances perçues d'avance
Dans la mesure où, dans le calcul de la provision, ces obligations ont été prises en considération, le montant de la provision devrait être réduit. 12 Canderel Ltd. v. ...