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Results 141 - 150 of 199 for consideration
Ministerial Correspondence
27 April 1990 Ministerial Correspondence 59514 F - Unpaid Remuneration
In our view, similar considerations apply with respect to subsection 78(4). ...
Ministerial Correspondence
10 April 1991 Ministerial Correspondence 910594 F - Shareholder/Employee Remuneration
We are therefore unable to provide specific confirmation as to the deductibility of the bonuses mentioned in your example but would suggest take these factors into consideration in deciding on the amount of bonuses to be charged to 24(1) operations. ...
Ministerial Correspondence
14 November 1991 Ministerial Correspondence 912654 F - Attribution Rules
14 November 1991 Ministerial Correspondence 912654 F- Attribution Rules Unedited CRA Tags 74.1(1), 74.3(1) Dear Sirs: Re: Attribution Rules This is in reply to your letter of August 26, 1991 addressed to the Vancouver District Office which was forwarded to this office for consideration and reply. ...
Ministerial Correspondence
28 February 1991 Ministerial Correspondence 910144 F - Reserves - Assumption of a Mortgage
Our Comments Generally, the reasonableness of a reserve will be acceptable if in the calculation of the reserve, consideration is given to any mortgages assumed by a buyer in situations where the vendor has previously given a mortgage to a third party either at the time of acquisition of the land or to finance the cost of improvements to the land including construction of a building on the land. ...
Ministerial Correspondence
10 January 1990 Ministerial Correspondence 58844 F - Computer Software
Income Tax Convention (1980) (the "Convention") defines the term "royalties (for purposes of that article) to mean"...Payments of any kind received as consideration for the use of, or the right to use, any copyright of literary... work... or for the use of, or the right to use, tangible personal property or for information concerning industrial, commercial or scientific experience... ...
Ministerial Correspondence
14 July 2011 Ministerial Correspondence 2010-0386191M4 - Canadian withholding taxes
Before discussing tax considerations, I would like to comment on two of your observations about Internet telephone services. ... I am forwarding a copy of our correspondence to senior CRA officials for their consideration in future compliance activity reviews. ...
Ministerial Correspondence
4 July 1990 Ministerial Correspondence 900954 F - Charity not Qualifying as Non-profit Organization
Your concerns regarding business activities carried on by non-profit organizations relate to tax policy considerations. While our Department is responsible for the administration of the Act, the Department of Finance is the appropriate authority to which to refer matters relating to tax policy considerations. ...
Ministerial Correspondence
2 July 2014 Ministerial Correspondence 2014-0537231M4 - Local Exchange Trading System
How barter transactions are taxed depends on the circumstances of the persons who are bartering and the nature of what is bartered, on the same basis as if cash were the consideration. ...
Ministerial Correspondence
7 July 2014 Ministerial Correspondence 2014-0532311M4 - child support amount
I am therefore sending a copy of our correspondence to the Honourable Joe Oliver, Minister of Finance, for his consideration. ...
Ministerial Correspondence
27 March 2014 Ministerial Correspondence 2014-0518601M4 - Non-qualified investments held in registered plans
I am therefore sending a copy of our correspondence to the Honourable Joe Oliver, Minister of Finance, for his consideration. ...