Search - considered
Results 1971 - 1980 of 2494 for considered
Technical Interpretation - Internal summary
17 December 2003 Internal T.I. 2003-0047727 F - Right of Use-Deemed Trust -- summary under Subsection 105(2)
After noting that under s. 248(3)(b), the right of use was deemed to be a trust and the property was deemed to have been transferred to that trust, the Directorate went on to indicate that s. 105(2) could apply “to all or part of the expenses actually incurred by Opco that could reasonably be considered to be attributable to the portion of the Immovable occupied by Sister as a place of residence” and that any “portion of the amount that would be included under subsection 105(2) in computing Sister's income may be deducted in computing the trust's income pursuant to paragraph 104(6)(b).” ...
Technical Interpretation - Internal summary
17 February 2004 Internal T.I. 2003-0046981I7 F - Paragraphe 98(5) de la Loi -- summary under Subsection 98(5)
However, subsection 98(5) may apply if the interests are sold successively and all other conditions of that subsection are satisfied since the corporation is considered to have been a member of the partnership immediately before the partnership ceased to exist. ...
Technical Interpretation - External summary
28 January 2004 External T.I. 2003-0028891E5 F - Perte sur change relative à des contrats de change -- summary under Paragraph 18(1)(e)
., by delivery of the currency), then the expense could only be considered to have been "incurred" within the meaning of paragraph 18(1)(a) from that time”, or under s. 18(1)(e) if there was “uncertainty as to the payment of the debt.” ...
Technical Interpretation - External summary
29 March 2004 External T.I. 2003-0040581E5 - Section 110.5 and Foreign Tax Credit -- summary under Section 110.5
It could not increase its taxable income under section 110.5 in year 10 in order to be considered to have U.S. source income for Canadian foreign tax credit purposes in year 10. ...
Technical Interpretation - External summary
13 April 2004 External T.I. 2003-0052291E5 F - Participation exclue - Par. 40(3.15) de la Loi -- summary under Subsection 40(3.15)
After noting that it was a question of fact whether there indeed had been a cessation of an active business (and noting in this regard that “a manufacturing business could downsize by subcontracting some of its operations and still be considered an active business”), CRA went on to indicate that it appeared that if there were such a change, the partnership would now satisfy the “income from property” branch of the test, so that the partnership interest continued to be an excluded interest, stating: [I]f the partnership has held the real property since February 22, 1994 and has derived income (business or property) from it since that time, we are of the view that the interest in such a partnership still constitutes an "excluded interest" as defined in subsection 40(3.15) to the extent that it meets all the other conditions set out there. ...
Technical Interpretation - External summary
22 June 2004 External T.I. 2004-0060211E5 F - Allocation pour utilisation d'un véhicule à moteur -- summary under Paragraph 6(1)(b)
In finding that the allowance likely was not taxable under s. 6(1)(b), CRA stated: [T]he trips made by the representative with his motor vehicle to go from the employee’s residence to the first client place of business and from the last client place of business to the individual’s residence could be considered to be trips made in the performance of the duties of his office or employment, as long as such client places of business do not constitute a regular place of work to the individual. … [I]t is unlikely that the clients' places of business would constitute a regular place of work of the representative. ...
Technical Interpretation - External summary
30 July 2004 External T.I. 2004-0063811E5 F - Soutien administratif à une filiale -- summary under Clause 37(8)(a)(ii)(A)
After referring to s. 37(13), CRA stated: [A]dministrative support tasks in respect of the activities of a subsidiary of a taxpayer would not be considered to be SR&ED of the taxpayer because the condition in paragraph 37(13)(b) is not satisfied since the administrative support tasks would not be SR&ED of the subsidiary …. ...
Technical Interpretation - Internal summary
3 August 2004 Internal T.I. 2004-0077991I7 F - Allocations d'aide à domicile reçues de la SAAQ -- summary under Paragraph 3(a)
He considered that the complainant had not intended to make a profit in this particular situation and that she would have taken care of her daughter even if she had not received any money for that care. ...
Technical Interpretation - External summary
15 October 2004 External T.I. 2004-0068421E5 F - Bien de remplacement -- summary under Subsection 44(5)
CRA indicated that “there is nothing in the wording of subsections 44(5) and 13(4.1) that would lead to the conclusion that the acquisition of a replacement property from a related person or from a corporation in which the taxpayer holds shares is prohibited for the purposes of these provisions” – although it indicated that whether s. 69 or 15 applied would need to be considered. ...
Technical Interpretation - External summary
23 September 2004 External T.I. 2004-0088801E5 F - Stop-Loss Provisions -- Grandfathering -- summary under Subsection 112(3.2)
If preferred shares of the corporation are issued to the individual as a stock dividend on the common shares, would those preferred shares qualify for the transitional relief on the basis of being considered to have been held on and after April 26, 1995, given that s. 248(5)(b) deems a share received as a stock dividend on another share of the capital stock of a corporation to be property substituted for that other share? ...