Search - considered

Where renewal or extension periods are considered part of the life of the property under the criteria set out in ¶ 15 above, and where the number of such renewals or extensions is indefinite, the property is not for a limited period and does not qualify as a class 14 property. ... Provisions, including force majeure and contingency termination clauses, which may result in an early termination of the life of a property are not considered relevant in determining the life of the property and whether or not the property is for a limited period. ... A registered industrial design is considered to be a franchise for a limited period and the life of the property on initial registration is 10 years. ...

Ruling Given Based on the facts set out above, the amount paid upon the signing of a merchandising agreement is considered to be “an amount in return for the promotion of the particular property by the particular registrant”. ... Ruling Given Based on the facts set out above, the allowance given to display Manufacturer A’s trademark on the packaging of the frozen pie shells is not considered to be a qualifying allowance for purposes of section 232.1. ... Ruling Given Based on the facts set out above, the allowance given to not stock a competing manufacturer’s product is considered to be “an amount in return for the promotion of the particular property by the particular registrant”. ...

The language used on the site was generally considered understandable, however, it seemed that Individuals tended to skip over or ignore words they did not understand. There are a number of links on the Home page that were considered misleading or confusing. ... The language used on the site was generally considered understandable. ...

The definition is also amended so that a specified RDSP payment and an accumulated income payment will not be considered an advantage for the purposes of subsection 205(1) of the Act. ... An AIP is considered an education savings rollover amount when paid into an RDSP. ... It must also specify that these amounts are only considered contributions for the purposes of paragraphs 146.4(4)(f) to (h) and (n) of the Act. ...

The conditions set out in paragraphs 8516(2)(a) through (d) of the Regulations have to be satisfied before the contributions can be considered eligible contributions. ... The PBSA or similar law of a province must clearly mandate that certain retirement benefits must be assumed to be provided or certain assumptions must be used before the contributions can be considered eligible contributions. Also the conditions set out in paragraphs 8516(3)(a) through (d) of the Regulations have to be satisfied before the contributions can be considered eligible contributions. ...

A builder who is considered to have collected the HST on a self-supply is required to report that amount on its GST/HST return for the reporting period during which the self-supply occurred. ... Rebate when taxable sale of new housing is made A GST/HST rebate is generally available to a non-registrant builder at the time the builder makes a taxable sale of new housing to another person or is considered under the self-supply rules to have made a taxable sale of the new housing. ... New residential rental property rebates The new residential rental property rebate in respect of the federal part of the HST that a non-registrant builder is considered to have collected on a self-supply of new housing continues to be available to eligible builder-landlords and is not affected by the HST rate increases in New Brunswick and Newfoundland and Labrador. ...

At this point, both the basic services and the number and kinds of additional services provided for, or made available to, tenants must be considered. ... For purposes of this paragraph and 12 above, to be considered "actively engaged in the business" of a partnership, a partner would normally be expected to contribute time, labour and attention to that business to a sufficient extent that such contributions would be a determinant in the successful operation of the business. ... Whether the renting of real property by an individual is a business or not, the depreciable property (ie. a building other than a building of Class 31 or 32) is considered a "rental property" for purposes of capital cost allowance. ...

. ¶3.8 (formerly included in ¶6 of IT-75R4) has been expanded to include certain skills (such as certified first aid and truck driver training courses) in the list of examples of the fields of study to which a scholarship or bursary may be considered to apply. ¶3.9 (formerly included in ¶6 of IT-75R4) has been expanded to include additional examples of the types of educational expenses that may fall within the scope of subparagraph 56(1)(n)(i) if paid or reimbursed through a scholarship or bursary program, in line with various CRA interpretations. ¶3.10 has been added to note that the taxability of a scholarship or award in an employment situation is dependent upon the particular facts and circumstances in each case. ¶3.11- 3.20 outline the most common types of arrangements and the tax implications under each. ¶3.12 (formerly included in ¶7 of IT-75R4) has been expanded to note the exception for employer-paid or reimbursed education-related expenses that are determined to be primarily for the benefit of the employer as well as to discuss the impact of any potential commitment to repay all or a portion of an award on the taxability to the recipient. ¶3.13 (formerly included in ¶12 of IT-340R) has been added to describe the circumstances upon which a student may deduct the repayment of an award previously received in respect of an office or employment pursuant to paragraph 8(1)(n). ¶3.16 has been added to note that awards described in ¶3.14 will be considered a repayable award if the student is committed to repay all of a portion of the scholarship or bursary in the future under certain circumstances. ¶3.17- 3.20 (formerly included in ¶9 of IT-75R4) have been expanded and substantially amended to distinguish the tax implications arising with respect to employer-provided scholarship or bursary awards to family members of employees in arm’s length or non-arm’s length situations, and in respect of elementary and secondary or post-secondary education. ... In particular ¶3.28- 3.30 has been added to discuss the circumstances in which an award may be considered employment income of the recipient. ... Subparagraph 56(1)(r)(v) was added by 2009, c. 2, s. 13(2), applicable to the 2008 and subsequent tax years. ¶3.81 has been added to describe the taxation of certain assistance received by an individual in connection with their participation in an employment-related activity, in line with various CRA interpretations on the subject matter. ¶3.84- 3.85 have been added to note that certain payments may be considered social assistance under paragraph 56(1)(u) or a scholarship or bursary under paragraph 56(1)(n) depending on its primary purpose, in line with CRA interpretations and jurisprudence. ¶3.87 (formerly ¶41 of IT-75R4) has been revised to reflect the amendment to Article XX of the Convention between Canada and the United States of America with Respect to Taxes on Income and on Capital pursuant to the coming into force of the Fifth Protocol. ...

In making a determination under section 68, the matter is to be considered from the viewpoint of both the vendor and the purchaser. ... In these latter circumstances, the demolition of the building is considered a disposition and may result in a capital loss in the purchaser's hands. ... Where the land area disposed of exceeds that necessary for the use of the building, paragraph 13(21.1)(a) is considered to apply only in respect of the portion that is necessary for the use of the building. ...

A builder who is considered to have collected the HST on a self-supply is required to report that amount on its GST/HST return for the reporting period during which the self-supply occurred. ... Rebate when taxable sale of new housing is made A GST/HST rebate is generally available to a non-registrant builder at the time the builder makes a taxable sale of new housing to another person or is considered under the self-supply rules to have made a taxable sale of the new housing. ... New residential rental property rebates The new residential rental property rebate in respect of the federal part of the HST that a non-registrant builder is considered to have collected on a self-supply of new housing continues to be available to eligible builder-landlords and is not affected by the HST rate increase in Prince Edward Island. ...