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Taxpayers must have gross revenues of less than $50 million or a proposed covered transaction of less than $10 million to be considered for the Program. ... A functional analysis must contain the records or documents listed under paragraph 247(4)(a) of the Income Tax Act, except for subparagraph 247(4)(a)(v) “data and methods considered.” ...

The reader should, therefore, consider such comments in light of the relevant provisions of the law in force for the particular taxation year being considered, taking into account the effect of any relevant amendments to those provisions or relevant court decisions occurring after the date on which the comments were made. ... However, for simplicity, where a taxpayer has a pre-1972 and a post-1971 pool of identical shares and the post-1971 pool contains a fraction of a share (e.g., a fraction received as a stock dividend), the disposition of the fraction may be considered to be a disposition from the post-1971 pool, even though the pre-1972 pool was not exhausted at that time. ...

An employee who takes time away from their duties and takes on that task as well could be recognized and that could be considered a valid award. ... Host: How would something like a voucher play into that, would that be considered near-cash as well? ...

Normally, it is considered reasonable to assume that the profit element in any amount due is that proportion of such amount that the gross profit on the sale bears to the gross selling price; thus a reserve might be allowed equal to the full amount of the profit if no part of the selling price had been received. ... A claim for a reserve equal to the lesser of the gross profit on the sale and the amount due will not be allowed as it is not considered reasonable to assume that the vendor receives no profit until after the full investment in the property sold has been recovered. 13. ...

Consistent with IIA standards, business advisory services are considered as recommended alternative where that type of engagement is most effective way of improving controls and risk management; however, business advisory services are considered on an exception basis only; 94% direct hours providing assurance services, 6% towards business advisory services. ...

Consequently, a deduction is not allowed for what might otherwise be considered to be the capital element of an amount so received. ... Payments under the contract will be considered annuity payments with a capital element equal to the applicable portion of the original cost of the annuity that was included in income. ...

Accounts that do not respond to early intervention measures are considered higher risk, require human intervention, and are referred for escalating enforcement action. ... During 2012-2013, in addition to the deliverables noted, the CRA will develop a formal SR&ED Stakeholders Engagement Strategy that will ensure that the needs and views of stakeholders continue to be considered during the planning, development, and implementation of administrative changes to the program. ...

., they have not considered an alternative to paper files), and that they are concerned about exclusively electronic storage because a computer virus or technical problem could destroy or prevent access to their documents. ... Some participants considered an email notification to be integral to the service. ...

The courts have directed that connecting factors must be considered when making this determination. ... Note The central management and control of an organization is usually considered to be exercised by the group that performs the function of a board of directors of the organization. ...

Indirect support could include, for example, a charity that puts a link on its website to a candidate's website; while the charity might not be saying "vote for this candidate," the link could be considered an attempt to get more visitors to the candidate's website, and therefore help that candidate in the campaign for public office. ... This would likely be considered connected to its charitable purposes. ...