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TAXATION: While Canadian Municipalities are exempt from tax under the Income Tax Act, such amounts would still be required to be taken into consideration in the computation of income. ...

" The first consideration should therefore be to determine the purpose of the legislation, whether as a whole or as expressed in a particular provision. ...

The primary consideration from an income tax perspective is whether the costs for such in-house care are deductible from income. ...

Other Issues Pertaining to Both Treaties Your Views In considering the application of both the U.K and Dutch Treaties with respect to the phrase "in connection with the offshore resources" a possible allocation problem must be taken into consideration. ...

We have given full consideration to the excerpts from XXX but we do not find it to be of any assistance in providing a technical interpretation of subparagraph 66.1(6)(a)(iii.1). 15. ...

Accordingly, we believe that an important consideration, inter alia, would be whether the old plan could be regarded as one under which an employer has made a contribution for the purposes of paragraph 6(1)(f) of the Act. ...

POSITION OF THE DEPARTMENT OF FINANCE 1) From a tax policy perspective, it is clear that each expenditure under consideration as an SR&ED expenditure must meet the required criteria (i.e., it must meet the tests in subparagraph 37 (7) (c) (ii)). ...

In so far, however, as the capital additions and improvements were received as consideration for agreeing to deliver 60 cycle power at a price that was lower than would otherwise have been economic, I should be inclined to think that it was probably received on revenue account in accordance with the ordinary principles of commercial trading. ...

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.” ...

Succession a transféré XXXXXXXXXX actions de catégorie « A » du capital-actions de Société (ci-après les « Actions Transférées ») en faveur de Nouco, en considération de XXXXXXXXXX actions de catégorie « A » du capital-actions de Nouco, à savoir des actions avec droit de vote et participantes, et du Billet 1, du Billet 2, du Billet 3 et du Billet 4 (collectivement les « Billets ») ne portant pas intérêt, en paiement absolu et complet. ...