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Administrative Policy summary

91 C.R. - Q.7 -- summary under Subsection 191(2)

.- Q.7-- summary under Subsection 191(2) Summary Under Tax Topics- Income Tax Act- Section 191- Subsection 191(2) The beneficiary of a trust owning shares of a corporation is not itself considered to have a substantial interest. ...
Administrative Policy summary

85 C.R. - Q.17 -- summary under Subsection 31(1)

.- Q.17-- summary under Subsection 31(1) Summary Under Tax Topics- Income Tax Act- Section 31- Subsection 31(1) The Graham decision does not provide any additional guidelines to those set out in IT-322R; factors considered in applying s. 31 are listed. ...
Administrative Policy summary

93 C.M.TC - Q. 12 -- summary under Corporation

93 C.M.TC- Q. 12-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation The limited liability companies for the two states that RC has reviewed (Wyoming and Florida) are considered to be corporations rather than partnerships. ...
Administrative Policy summary

90 C.R. - Q43 -- summary under Subsection 249(4)

.- Q43-- summary under Subsection 249(4) Summary Under Tax Topics- Income Tax Act- Section 249- Subsection 249(4) In the absence of the application of s. 256(8), control of a corporation normally will be considered to be acquired on the date of closing. ...
Administrative Policy summary

88 C.R. - Q.20 -- summary under Subsection 98(1)

.- Q.20-- summary under Subsection 98(1) Summary Under Tax Topics- Income Tax Act- Section 98- Subsection 98(1) Where a partnership is in receivership, property held for distribution to creditors is considered to be "partnership property" until it is so distributed. ...
Administrative Policy summary

87 C.R. - Q.79 -- summary under Subsection 116(2)

.- Q.79-- summary under Subsection 116(2) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(2) A bank guarantee, mortgage or deposit agreement enforceable in Canada normally would be considered as acceptable security. ...
Administrative Policy summary

84 C.R. - Q.16 -- summary under Subsection 15(2)

.- Q.16-- summary under Subsection 15(2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2) "Taxpayer" in s. 20(1)(j) is considered to include a partnership where a loan subject to s. 15(2) previously has been included in the partnership's income. ...
Administrative Policy summary

84 C.R. - Q.16 -- summary under Taxpayer

.- Q.16-- summary under Taxpayer Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Taxpayer "taxpayer" in s. 20(1)(j) is considered to include a partnership where a loan previously has been included in the partnership's income. ...
Administrative Policy summary

84 C.R. - Q.50 -- summary under Subsection 87(8.1)

.- Q.50-- summary under Subsection 87(8.1) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(8.1) Where one or more predecessor corporations continue in the form of one corporate entity, that corporate entity is considered to be a new foreign corporation. ...
Administrative Policy summary

93 C.P.T.J. - Q.23 -- summary under Paragraph 6(1)(a)

.- Q.23-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Where a vehicle (whether owned by the employee or the employer) is regularly required to be used during business hours in the carrying out of employment duties, the value of a parking facility provided by the employer for the vehicle is not considered to be a taxable benefit. ...

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