Search - considered
Results 4391 - 4397 of 4397 for considered
Administrative Policy summary
Income Tax Technical News, No. 30, 21 May 2004 -- summary under Paragraph 96(1)(f)
The Tax Court of Canada considered this issue in Crestglen Investments Limited [f.n. 9: Crestglen Investments Limited v. ...
Administrative Policy summary
GST/HST Memorandum 14-9-1 “Partnerships - Determining the Existence of a Partnership” March 2025 -- summary under Section 96
In addition, an activity that might not ordinarily be classified as a business (such as buying, selling and holding investments) may be considered as such if it is carried on as a business endeavour. … 29. … [T]he fact that a partnership is formally registered under partnership law does not necessarily mean that a partnership (or business) actually exists. ...
Administrative Policy summary
30 June 2005 GST/HST Interpretation 57840 - XXXXX eligibility for relief of GST -- summary under Subsection 272.1(1)
30 June 2005 GST/HST Interpretation 57840- XXXXX eligibility for relief of GST-- summary under Subsection 272.1(1) Summary Under Tax Topics- Excise Tax Act- Section 272.1- Subsection 272.1(1) 2%-of-NAV component of GP's compensation subject to s. 272.1(3) Where the general partner of an investment limited partnership is entitled to proportionate sharing of profits with limited partners (based on respective units held) together with an amount equal to 2% of the net asset value of the assets of the partnership, the 2% amount (described by CRA as a "fee") generally will be considered to be remuneration for services provided by the partner on its own account and not for something done as a member of the partnership even if the agreement to provide the services is included in the partnership agreement. ...
Administrative Policy summary
10 February 2017 GST/HST Ruling 162056 - Application of the GST/HST to an investment transaction -- summary under Subsection 169(1)
However, when Corporation 1 makes the subsequent Royalty Payments to Investor pursuant to the right that Investor has acquired, Investor is not considered to be making a taxable supply in exchange for those payments. ...
Administrative Policy summary
10 February 2017 GST/HST Ruling 162056 - Application of the GST/HST to an investment transaction -- summary under Commercial Activity
After ruling that the lump sums so paid are consideration for the taxable supply to Investor of intangible personal property (the right to the royalty payments), CRA went on to find that when Corporation 1 makes the subsequent Royalty Payments to Investor pursuant to the right that Investor has acquired, Investor is not considered to be making a taxable supply in exchange for those payments. ...
Other Admin Summary
22 July 2013 GST/HST Interpretation 145125 - Condominium units and the exclusions to the definition of residential complex -- summary under Residential Complex
" Respecting the application of the 90% Test, the correspondent's "suggested method, the number of supplies made by way of lease, licence or similar arrangement, appears to be equivalent to the "Invoice Method" in P-053, which is considered not to be an acceptable method. ...
Administrative Policy summary
10 February 2017 GST/HST Ruling 162056 - Application of the GST/HST to an investment transaction -- summary under Subsection 182(1)
However, when Corporation 1 makes the subsequent Royalty Payments to Investor pursuant to the right that Investor has acquired, Investor is not considered to be making a taxable supply in exchange for those payments. ...