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Administrative Policy summary

89 C.R. - Q.32 -- summary under Other

.- Q.32-- summary under Other Summary Under Tax Topics- General Concepts- Fair Market Value- Other The fact that a government agency might not grant a renewal of a taxi licence, timber licence or other quota in the nature of government rights is considered by each RC valuator. ...
Administrative Policy summary

Information for Non-Profit Organizations under "Registering for the GST" -- summary under Person

Information for Non-Profit Organizations under "Registering for the GST"-- summary under Person Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Person An office or branch within an unincorporated organization will be considered a separate person if it has a significant degree of control over its own affairs. ...
Administrative Policy summary

GST M 300-5 "Place of Supply" -- summary under Subsection 132(1)

GST M 300-5 "Place of Supply"-- summary under Subsection 132(1) Summary Under Tax Topics- Excise Tax Act- Section 132- Subsection 132(1) The factors considered for income tax purposes in determining the residency of an individual provide some guidelines for determining whether he is resident for GST purposes. ...
Administrative Policy summary

87 C.R. - Q.35 -- summary under Reasonable Expectation of Profit

.- Q.35-- summary under Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Reasonable Expectation of Profit In determining whether an activity has a reasonable expectation of profit, discretionary deductions should be considered if they are relevant in computing "profit" as determined under GAAP. ...
Administrative Policy summary

87 C.R. - Q.35 -- summary under Business Source/Reasonable Expectation of Profit

.- Q.35-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit In determining whether an activity has a reasonable expectation of profit, discretionary deductions should be considered if they are relevant in computing "profit" as determined under GAAP. ...
Administrative Policy summary

85 C.R. - Q.20 -- summary under Paragraph 2(3)(b)

.- Q.20-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) A non-resident partner of a partnership carrying on business in Canada is considered to be carrying on business in Canada and therefore is taxable under Part I. ...
Administrative Policy summary

91 C.R. - Q.36 -- summary under Subsection 181.2(3)

.- Q.36-- summary under Subsection 181.2(3) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3) Where there has been a write-down in accordance with GAAP to reflect other than a temporary decline in the value of a capital asset, the write-down will not be considered to be a "reserve". ...
Administrative Policy summary

84 C.R. - Q.33 -- summary under Paragraph 104(15)(b)

.- Q.33-- summary under Paragraph 104(15)(b) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(15)- Paragraph 104(15)(b) An alternate beneficiary who has succeeded to the income rights of a deceased discretionary beneficiary will be considered to be a discretionary beneficiary unless under the trust deed he has acquired a fixed right to a share of the accumulating income of the trust. ...
Administrative Policy summary

84 C.R. - Q.35 -- summary under Section 114

.- Q.35-- summary under Section 114 Summary Under Tax Topics- Income Tax Act- Section 114 A non-resident who only occasionally visits Canada to perform directorship duties will not thereby be considered to be employed in Canada throughout the period after he left Canada. ...
Administrative Policy summary

Income Tax Technical News, No. 7, 21 February 1996 (cancelled) -- summary under Subsection 249(4)

Income Tax Technical News, No. 7, 21 February 1996 (cancelled)-- summary under Subsection 249(4) Summary Under Tax Topics- Income Tax Act- Section 249- Subsection 249(4) Discussion of when shareholders of a closely-held corporation are considered to be acting in concert or otherwise to represent a group. ...

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