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Administrative Policy summary

GST/HST Notice 312 Proposed GST/HST Treatment of Supplies of Human Ova and In vitro Embryos May 2019 -- summary under Section 6

Consequently, the importation of an ovum would be considered a non‑taxable importation for GST/HST purposes under section 6 of Schedule VII to the Act and therefore no longer subject to tax. Similarly, an ovum brought into a participating province from a non-participating province, or from another participating province for which the rate of the provincial part of the HST is lower, would be considered non-taxable property for GST/HST purposes under section 15 of Part I of Schedule X to the Act and therefore no longer subject to self-assessment for the provincial component of the HST, or part thereof. ...
Administrative Policy summary

Guidance on the income tax measures to support journalism CRA Webpage 23 December 2019 -- summary under Subparagraph (a)(v)

The reproduction of material produced by another organization would not be considered original news content of the organization and will factor into the determination of whether an organization is primarily engaged in the production of original news content. 2.28. Activities or publications that focus primarily on the following would not be considered the production of original news content: industry-specific publications, trade journals, travel magazines, sports or entertainment news; the rewriting, translation, reproduction or aggregation of news from external sources (including articles from news agencies, a current or previous issue of the same publication or any other publication); advertisements, listings, catalogues, directories, guides, financial reports, schedules, calendars, timetables, comic books, cartoons, puzzles, games and horoscopes; internal publications of companies, private or public bodies, or associations; and publication of content that is illegal in Canada. ...
Administrative Policy summary

Frequently asked questions - Canada emergency wage subsidy (CEWS) CRA Webpage 24 September 2021 -- summary under Paragraph 125.7(9)(b)

Since the prior claim period actual reduction (25%) is greater than the current claim period reduction (15%), the deeming rule applies and the reduction in revenue is considered to be 25% for claim period 5. ... Since the prior claim period actual reduction (15%) is greater than the current claim period reduction (0%), the deeming rule applies and the reduction in revenue is considered to be 15% for the claim period 6. ...
Administrative Policy summary

S3-F3-C1 - Replacement Property -- summary under Subsection 44(1)

The election should be made as follows: If the disposition and replacement take place in the same year, the taxpayer’s calculation (in the income tax return for that year) of the recaptured CCA or the capital gain by virtue of subsection 44(1) will be considered to constitute an election. ... This is because pursuant to paragraph 96(1)(a), the partnership is considered to be a person separate from its partners for purposes of income and loss computations under subdivision j. ...
Administrative Policy summary

89 C.R. - Q.49 -- summary under Capital Dividend Account

.- Q.49-- summary under Capital Dividend Account Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account A prior year's capital gains reserve is considered to come into the capital dividend account calculation at the beginning of the year. ...
Administrative Policy summary

91 CPTJ - Q.1 -- summary under Subsection 69(11)

91 CPTJ- Q.1-- summary under Subsection 69(11) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(11) Whether the vendor has knowledge and control of the series of transactions may be considered when determining whether s. 69(11) applies. ...
Administrative Policy summary

81 C.R. - Q.55 -- summary under Subsection 104(24)

.- Q.55-- summary under Subsection 104(24) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(24) Where a particular beneficiary's entitlement to or share of the income of a trust is before the courts, the amount cannot be considered to be payable. ...
Administrative Policy summary

December 2000 TEI Round Table, Q. XXVIII -- summary under Subsection 163.2(15)

XXVIII-- summary under Subsection 163.2(15) Summary Under Tax Topics- Income Tax Act- Section 163.2- Subsection 163.2(15) An officer of a corporation will be considered to be an "employee... employed by the" corporation in applying s. 163.2(15). ...
Administrative Policy summary

October 1989 Revenue Canada Round Table - Q.18 (Jan. 90 Access Letter, ¶1075) -- summary under Shares

October 1989 Revenue Canada Round Table- Q.18 (Jan. 90 Access Letter, ¶1075)-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares Listing of factors that are considered in assessing the size of a minority discount. ...
Administrative Policy summary

IC 89-3 "Policy Statement on Business Equity Valuations" -- summary under Subsection 70(5)

IC 89-3 "Policy Statement on Business Equity Valuations"-- summary under Subsection 70(5) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(5) Discussion of the circumstances in which a buy-sell agreement will be considered determinative of value for purposes of s. 70(5). ...

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