Search - considered

Income from the rental of real estate is generally considered to be income from property. ... The amount received by the Spouse may therefore be considered a refund of premiums without any further formality. ... (b) Is the safe income from the sale of the assets lost or will it be considered in a future computation of safe income? ...

Preliminary response Prud’Homme: We have considered the remaining issues that were submitted by the Joint Committee. ... A would be considered to be derived directly or indirectly from a related business, which was the Old Business. ... A in the current year from Aco would be considered to be an excluded amount and would not be subject to TOSI. ...

Considered contextually I think the word “asset” was used in an all-embracing sense... ... These criteria must be considered in relation to each other, and not as separate criteria. ... However, in a context where the landlord pays compensation to his tenant because of his obligations under the Civil Code of Québec, this element could then be considered dominant and the compensation could be considered a current expense. ...

-dollar debentures (where the underlying shares have appreciated even if the U.S. dollar has appreciated) being considered to have realized a loss. ... Taxpayers and their representatives should be assured that when the application of the GAAR is considered, all their arguments will receive careful consideration. ... Has the CRA8 considered reaching out to the IRS on this matter to streamline the process of obtaining verification of credits claimed. ...

In such a scenario, could part of the services rendered by USco be: A. considered “services rendered in Canada” for purposes of Regulation 105; and B. considered “services… provided in that other State" for purposes of Article V:9(b) of the Canada-U.S. ... For example, instances where a trust pays the tuition fees or repays a loan taken up by another person are to be considered indirect distributions by the trust. ... T1134 Missing Substantial Information (for 2021 and later taxation years) In technical interpretation 2019-0791541I7 the CRA indicated that an information return missing substantial information will be considered invalid, and therefore, will not be considered to have been filed. ...

For example, it has been suggested in the past that normal course or ordinary course dividends should not be considered to have a purpose described in proposed s. 55(2.1)(b). ... Three potential bad purposes In terms of the factors that will be considered in determining the purpose of a dividend, we would like to reiterate what we said at the 2015 CTF Roundtable that, in a sense, the purpose test is a purpose test, it is not a results test. ... The first one is the allocation of the safe income to that share, so that such allocation would have to be done- and the words of the provision are that the safe income exception applies to the extent that it could reasonably be considered to contribute to the gain on the share. ...

The GAAR committee considered similar transactions. The purpose of s. 212.1(1) is to prevent the foreign parent from accessing Canadian corporate surplus. ... In addition, the US business has been equal to, or larger than, the Canadian operations in the majority of situations considered. ... This may be the case where it could be considered that the share ownership in the foreign affiliate is transitory on the basis that it is reasonable to conclude that a subsequent disposition was contemplated at the outset. ...

A bill of lading would be considered a “contract for carriage” in the common law provinces. ... For this reason, not only would Quebec Co. not be considered to have retained the carrier on behalf of Ontario Co. as acknowledged in the question, but it would also not be considered to have shipped the widgets. ... The transaction is considered “revenue neutral” as no ITC was claimed. ...

Again, the circumstances have to be considered. If USco still has to approve the transaction or the contract, but that step is a formality, the conditions could be met. ... Other considerations would have to be considered if USco has Canadian employees or employees working in Canada. ... Regarding the second leg of the distribution to the fiscally disregarded US LLC 1, the REIT would be considered to meet the conditions of Art. ...

Changes planned for 2023 include restructuring the ReFILE foundation to ensure that all the taxpayer’s latest assessed data are considered automatically. ... Some change requests are considered complex and will take longer. Due to COVID-19, the timeframe for processing adjustment requests submitted by paper can be 10 to 12 weeks. ... Some change requests are considered complex and will take longer to process. ...