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Technical Interpretation - External summary

16 March 2015 External T.I. 2014-0521791E5 - Estate Trustee Fees -- summary under Office

CRA responded: Where the estate trustee is a person who does not act in this capacity in the course of carrying on a business, the fee for acting as estate trustee is considered to be income from an office. ...
Ruling summary

2012 Ruling 2011-0402571R3 - De Jure Control - Debt Settlement -- summary under Subparagraph 251(2)(b)(i)

The ruling summary indicates that Parent is considered to have de jure control of Lossco (notwithstanding that it does not have an immediate right to elect a majority of the directors of Lossco) and that this is "consistent with the decision of the SCC in Donald Applicators Ltd. (1969). ...
Ruling summary

2012 Ruling 2011-0402571R3 - De Jure Control - Debt Settlement -- summary under Paragraph 256(7)(b)

The ruling summary indicates that Parent is considered to have de jure control of Lossco (notwithstanding that it does not have an immediate right to elect a majority of the directors of Lossco) and that this is "consistent with the decision of the SCC in Donald Applicators Ltd. (1969). ...
Technical Interpretation - External summary

14 March 2013 External T.I. 2012-0472361E5 F - Fournitures/outils - guides de pêche -- summary under Subparagraph 8(1)(i)(iii)

. … In order to determine whether an expense incurred by an employee, which was not expressly provided for in an employment contract, is in fact an implicit requirement of an office or employment, the courts have considered whether the fact of failure to comply could result in termination of employment, poor evaluation of employee performance or other disciplinary action by the employer. ...
Technical Interpretation - External summary

14 March 2013 External T.I. 2012-0472361E5 F - Fournitures/outils - guides de pêche -- summary under Paragraph 8(1)(s)

After discussion the potential deduction under s. 8(1)(i)(iii) (as to which the materials might qualify as “supplies”), CRA stated: Since there is no definition of the term "tradesperson" in the Act, this term should be interpreted in its ordinary meaning and it is our view that fishing guides could be considered as tradespeople. … [I]t appears that the property described in your letter is not tools. ...
Technical Interpretation - External summary

27 September 2012 External T.I. 2011-0412961E5 - NPO and Taxable Subsidiary -- summary under Paragraph 149(1)(l)

27 September 2012 External T.I. 2011-0412961E5- NPO and Taxable Subsidiary-- summary under Paragraph 149(1)(l) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(l) CRA noted that holding shares in a for-profit subsidiary will not necessarily disqualify an organization from the benefit of 149(1)(l)....if an organization holds shares to earn income from property, it may be considered to have a profit purpose, even if the income from those shares is used in furtherance of the organization's not-for-profit objectives. ...
Technical Interpretation - Internal summary

19 March 2013 Internal T.I. 2010-0385931I7 - Taxable Canadian property and Partnerships -- summary under Subsection 116(1)

Thus, for the purpose of determining whether the non-resident partner is taxable under subsection 2(3)…the partners of the partnership are considered to have disposed of their respective interest in the property of the partnership and paragraph 96(1)(c) does not apply….In other words, the "non-resident person" referred to in subsection 2(3) is the non-resident partner and not the partnership. ...
Technical Interpretation - Internal summary

19 March 2013 Internal T.I. 2010-0385931I7 - Taxable Canadian property and Partnerships -- summary under Paragraph (e)

Thus, for the purpose of determining whether the non-resident partner is taxable under subsection 2(3)…the partners of the partnership are considered to have disposed of their respective interest in the property of the partnership and paragraph 96(1)(c) does not apply….In other words, the "non-resident person" referred to in subsection 2(3) is the non-resident partner and not the partnership. ...
Conference summary

25 November 2012 CTF Roundtable, 2013-0479402C6 - Employee Buycos - comments from CRA Panel -- summary under Paragraph 251(1)(c)

Accordingly, in ruling requests on this type of transaction, considered in 2012, we refused to confirm that section 84.1 would not apply to deem employees to receive a dividend from a Buyco on the disposition of their Opco shares. ...
Technical Interpretation - External summary

2 October 2014 External T.I. 2013-0491411E5 F - Allocation pour une automobile -- summary under Section 3

In making this determination, the following factors should be considered in relation to the taxpayer's activities: time spent by the taxpayer on the activity; the number of days per week the taxpayer is available; the annual number of kilometers driven; and the total annual amount received by the taxpayer. ...

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