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IV(4) Under U.S. law, when a U.S. citizen dies, their estate may be considered a U.S. estate under U.S. domestic law. ... b) Can the CRA tell us what factors are considered by the competent authority when settling the issue? ... C’s income pursuant to s.104(13) would be considered to be US-source income – and we assume this throughout the rest of the answer. ...

The Committee also considered that such a transfer is an abuse or misuse of ss. 107(2), (2.1) and (5). ... A is deemed to receive are considered to be derived directly or indirectly from such investment business. ... Similarly, a notice in an annual or quarterly report that an eligible dividend has been paid is considered valid for that quarter. ...

If X settles a trust in 2013 with property, and then in 2017 Y contributes property to the trust, is the contribution by Y considered to fall under the word “settles”, and is Y considered a “settlor”? ... Q.7 Bitcoins as money or IPP 2013-0514701I7 stated: Virtual currencies, such as Bitcoins, are not considered to be a currency issued by a government of a country…. ... Nonetheless, it could be considered that the Property was still delivered or made available by Company B outside of Canada. ...

In the Bill C-63 proposed modification, the language that was in the original question was removed – it seems obvious that the wording was considered unnecessary. ... Paragraph 187 of the Commentary to new Article 29 sets out examples of treaty-shopping strategies commonly referred to as “conduit arrangements”, as well as arrangements that should not be considered to be conduit arrangements. ... Accordingly, in those situations where Amalco makes an election after the time that Targetco shares are delisted, Amalco will not be considered to be a public corporation. ...

The CRA interprets Schedule V as a list of exempt supplies that must be considered and applied independently. ... What aspects of the original policy statement were considered problematic so as to require removal of P-249? ... Is only the $1M considered taxable as the “amount paid” under s. 182 and GST/HST would be deemed included in this amount – so that the interest and indemnity amounts would be considered non-taxable? ...

In our view, the wording of paragraph (a) does not support the interpretation that the test is that the beneficiary’s interest must be acquired as a result of the particular transfer being considered. ... The proceeds received in respect of the disposition of a property of a trust would be considered substituted property. ... Fron: In each case, the deemed dividend that arises on ACo’s acquisition of its own shares would be considered to be paid by ACo in its new taxation year. ...

(d) Incapacitated taxpayer The situation described above would not be considered as an exclusion to EFILE. ... Would a beneficiary of a trust that has an interest in the corporation be considered to hold an interest? Would a trustee of a trust that has an interest in the corporation be considered to hold an interest? ...

The Queen (TCC) 2015 TCC 42], which considered the income or capital characterization of the taxpayer’s gains on foreign currency derivatives. ... Can the CRA confirm that it still follows this “two-step” approach, and can you update us on any new entities or arrangements that are being considered? ... (The German version of the Treaty was not considered to be an official version.) ...

S. 94(3) trust holding "CCPC" A trust which meets the conditions of section 94 is considered resident for certain purposes of the Act. ... Since subsection 94(3) does not state that a deemed resident trust is considered resident for purposes of determining control, we would imagine that the corporation would not be considered Canadian controlled. ... Recent TIs Can the CRA provide an update on some of the recent issues that it has considered relating to trusts and estates? ...

Notes From Presentation In brief, a guarantee made for no fee is considered to be an investment in the subject corporation (Forco) by the CRIC in these circumstances. ... Similarly, there is considered to be a conferral of a benefit when the CRIC guarantees debt of a subject corporation for no fee. ... The amount deductible is the amount that the taxpayer can demonstrate can reasonably be considered to have been deductible by the taxpayer pursuant to paragraph 113(1)(a) in respect of the exempt surplus of a FA of the taxpayer at the lending time, assuming that the amount lent was instead paid by the creditor affiliate or partnership as a dividend. ...