Search - considered

In the case of a common-law partnership, the taxpayer would not be considered to have a common-law partner in applying the first-time homebuyer condition. 2) In the case of either a marriage or common-law partnership, subsection 146.01(2.1) provides relief from the first-time homebuyer condition. ...

In particular, subparagraphs 12(1)(x)(ii) through (iv) would bring into income amounts received by a taxpayer from a government that      "... can reasonably be considered to have been received (iii)     as an inducement, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of inducement, or (iv)     as a reimbursement, contribution, allowance or as assistance, whether as a grant, subsidy, forgivable loan, deduction from tax, allowance or any other form of assistance, in respect of property or in respect of an outlay or expense". ...

To the best of your knowledge and that of the taxpayers involved: (i) none of the issues involved in the requested rulings is being considered by a Tax Services Office or a Taxation Centre in connection with a tax return already filed, and (ii) none of the issues involved in the requested rulings is the subject of any notice of objection or is under appeal. ...

Where property is transferred to a corporation in exchange for shares with a par value, the transferor is considered to have realized proceeds equal to the fair,market value of the shares end not their par value. ...

This is also true for the trustee/beneficiary who, in this particular situation, is not considered to have control over the decision to add a new beneficiary. ...

/The transaction will be considered of a capital nature and the capital gain if any, will depend on the proceeds of disposition. ...

We understand that to the best of your knowledge and that of each of the Taxpayers involved, none of the proposed transactions and/or issues involved in this ruling are the same as, or substantially similar to, transactions and/or issues that are: a. in a previously filed tax return of the Taxpayers or person related to the Taxpayers; b. being considered by the CRA in connection with a previously filed tax return of the Taxpayers or a person related to the Taxpayers; c. under objection by the Taxpayers or a person related to the Taxpayers; d. before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; and e. the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate of the CRA in connection with the Taxpayers or a person related to the Taxpayers. ...

We understand that, to the best of your knowledge and that of the Taxpayers, none of the proposed transactions and/or issues involved in this Ruling are the same as, or substantially similar to, transactions and/or issues that are: a) in a previously filed tax return of the Taxpayers or a person related to the Taxpayers; b) being considered by the CRA in connection with a previously filed tax return of the Taxpayers or a person related to the Taxpayers; c) under objection by the Taxpayers or a person related to the Taxpayers; d) before the courts or, if a judgment has been issued, the time limit for appeal to a higher court has expired; or e) the subject of an advance income tax ruling previously issued by the Income Tax Rulings Directorate in connection with the Taxpayers or a person related to the Taxpayers. ...

(2) Whether a corporate beneficiary receiving an interest in a life insurance policy from a trust as payment of a dividend in kind received by the trust should be considered as having given a consideration for the interest in the life insurance policy? ...

(2) Whether a corporate beneficiary receiving an interest in a life insurance policy from a trust as payment of a dividend in kind received by the trust should be considered as having given a consideration for the interest in the life insurance policy? ...