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Technical Interpretation - External summary

16 April 2015 External T.I. 2014-0561061E5 - Specified Foreign Property -- summary under Specified Foreign Property

. … Based on the limited description…the digital currency would be held outside of Canada and would not be considered to be used or held exclusively in the course of carrying on an active business. ...
Technical Interpretation - Internal summary

23 July 2014 Internal T.I. 2014-0525231I7 - Foreign tax credit -- summary under Non-Business-Income Tax

., Meyer] would lend support to the position that absent any evidence to the contrary the tax paid to the Japanese tax authorities was voluntary and as such, should not be considered to be a "tax" within the meaning of subsection 126(1). ...
Technical Interpretation - Internal summary

23 July 2014 Internal T.I. 2014-0525231I7 - Foreign tax credit -- summary under Article 24

After concluding that Canco would not be entitled to a FTC on the basis inter alia that "a taxable capital gain resulting from a deemed disposition of property is considered to be Canadian-source income, which therefore cannot be included in the foreign non-business income for purposes of claiming a FTC," the Directorate went on to state: Article 21 [of the Canada-Japan Treaty] deems gains of a resident of Canada, which are taxed in Japan under the Convention, to arise from a source in Japan and requires Canada to provide a credit in respect of such Japanese tax against any Canadian tax payable on such gains. ...
Technical Interpretation - External summary

5 February 2013 External T.I. 2012-0465591E5 F - Form T5018 -- summary under Subsection 238(1)

For example, some projects could be considered as the installation or improvement of a structure on the surface or sub-surface, the surface being the land or property. ...
Technical Interpretation - Internal summary

6 May 2014 Internal T.I. 2014-0524651I7 - Loss on conversion -- summary under Subsection 51(1)

It also stated: "We have not considered the application of GAAR to the conversion, but you may wish to consider it further. ...
Ruling summary

2012 Ruling 2012-0458361R3 - Cross-Border Financing -- summary under Article 4

For any interest paid by CCo to ECo in respect of the Charlie Debts, such interest will be considered to be derived by DCo pursuant to paragraph 6 of Article IV of the Treaty. ...
Conference summary

5 October 2012 APFF Roundtable Q. 13, 2012-0454181C6 F - Discretionary Dividend Shares -- summary under Subsection 15(1)

Indeed, Opco could be considered to have conferred a benefit on Holdco under section 15(1) when the shares were issued. ...
Technical Interpretation - External summary

7 February 2014 External T.I. 2014-0516921E5 F - Crédit et frais résiduels -- summary under A

…[T]he determination of the nature of the contractual relationship between the Employer and the Leasing Corporation is one of fact and law to be considered by the parties. ...
Ruling summary

2014 Ruling 2014-0530961R3 - Cross-Border Butterfly -- summary under Subparagraph 55(3.1)(b)(i)

In connection with the s. 55(3.1)(b)(i)(A)(II) rule, CRA indicated that indebtedness of Foreign SpinCo will be considered to reduce the FMV of each property of Foreign SpinCo pro rata in proportion to the relative FMV of all property of Foreign SpinCo. ...
Technical Interpretation - External summary

15 January 2015 External T.I. 2014-0546581E5 - Partnership interest excluded property -- summary under Excluded Property

Consequently, LP would not be considered to be a "foreign affiliate" of Canco 3 and Forco's interest in LP would not qualify as "excluded property"…. ...

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