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Administrative Policy summary
88 C.R. - Q.52 -- summary under Subsection 18(3.1)
.- Q.52-- summary under Subsection 18(3.1) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(3.1) Where a taxpayer has an ownership interest in a building being erected, the taxpayer is considered to have acquired the building to the extent of construction costs incurred to date, or progress billings received to date, as the case may be. ...
Administrative Policy summary
93 A.P.F.F. Round Table, Q.16 -- summary under Reserves
Round Table, Q.16-- summary under Reserves Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(1)- Reserves Where the value of a long-term investment has been written down as a result of a non-temporary decline in its value, such reduction will not be considered a "reserve". ...
Administrative Policy summary
May 1998 Conference for Advanced Life Underwriting Round Table, Q. 1, No. 9807000 -- summary under Paragraph 251(1)(c)
May 1998 Conference for Advanced Life Underwriting Round Table, Q. 1, No. 9807000-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) A donor and donee may be considered to have different interests and, therefore, to deal at arm's length notwithstanding that each party may have the same purpose such as the same charitable objective. ...
Administrative Policy summary
IT-129R "Lawyers' Trust Accounts and Disbursements" -- summary under Subsection 104(2)
IT-129R "Lawyers' Trust Accounts and Disbursements"-- summary under Subsection 104(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(2) Where funds are deposited with a lawyer by litigants for safekeeping and investment pending a court order or settlement, the income generated is regarded as income of the trust and the beneficial owner of the income will be considered to be the eventual recipient of the funds. ...
Administrative Policy summary
1990 Answers of the Scarborough District Office (May 1990 Acess Letter, ¶1200, Q. 7) -- summary under Paragraph 37(8)(d)
1990 Answers of the Scarborough District Office (May 1990 Acess Letter, ¶1200, Q. 7)-- summary under Paragraph 37(8)(d) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(8)- Paragraph 37(8)(d) Capital expenditures made in respect of refurbishing or renovating a pre-existing building are considered non-qualifying expenditures in respect of "the acquisition of a building" for purposes of s. 37(7)(f)(i). ...
Administrative Policy summary
88 C.R. - Q.27 -- summary under Salary Deferral Arrangement
.- Q.27-- summary under Salary Deferral Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement where tax deferral has been achieved, this would be a significant factor to be considered in RC's evaluation of the main purpose of the plan. ...
Administrative Policy summary
89 C.P.T.J. - Q13 -- summary under Subsection 1100(2.2)
.- Q13-- summary under Subsection 1100(2.2) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(2.2) A partnership will be considered to be a taxpayer for purposes of s. 1100(2.2)(e) and s. 1102(14)(b). ...
Administrative Policy summary
17 May 1993 Memorandum (Tax Window, No. 31, p. 12, ¶2523) -- summary under Paragraph 111(5)(a)
17 May 1993 Memorandum (Tax Window, No. 31, p. 12, ¶2523)-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) Losses from a rental property incurred by a corporation prior to an acquisition will continue to be available after the acquisition of control if the rental operation were considered to be a specified investment business. ...
Administrative Policy summary
IT-441 dated November 29, 1979 "Capital Cost Allowance - Certified Feature Productions and Certified Short Productions" -- summary under Depreciable Property
IT-441 dated November 29, 1979 "Capital Cost Allowance- Certified Feature Productions and Certified Short Productions"-- summary under Depreciable Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Depreciable Property Discussion of the requirements for a taxpayer to be considered to be the owner of a film. ...
Administrative Policy summary
IT-436R "Reserves - Where Promissory Notes are Included in Disposal Proceeds" -- summary under Payment & Receipt
IT-436R "Reserves- Where Promissory Notes are Included in Disposal Proceeds"-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Where a promissory note has been accepted as absolute payment for the disposition of a property, no amount is due in respect of the disposition, because the debt is considered to have been paid or satisfied by the receipt of the promissory note. ...