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Ministerial Correspondence
27 September 2006 Ministerial Correspondence 2006-0205151M4 - Income Splitting
Any proposed changes to tax policy or amendments to legislation would have to be considered by the Minister of Finance and approved by Parliament. ...
Technical Interpretation - External
20 December 2006 External T.I. 2006-0217041E5 - Subsections 188.1(3) and 149.1(12)
We can confirm that in determining whether a charitable foundation has acquired control of a particular corporation for the purposes of subsection 188.1(3) of the Act, the entirety of paragraph 149.1(12)(a) of the Act will be taken into account such that a foundation will not be considered to have acquired control of a corporation if it has not purchased or otherwise acquired for consideration more than 5% of the issued shares of any class of the capital stock of that corporation. ...
Ministerial Correspondence
9 February 2007 Ministerial Correspondence 2007-0220941M4 - Lifelong Learning Plan
Any changes to the legislation would have to be considered by the Minister of Finance and approved by Parliament. ...
Technical Interpretation - External
20 June 2005 External T.I. 2005-0134971E5 - QUALIFIED FARM PROPERTY
20 June 2005 External T.I. 2005-0134971E5- QUALIFIED FARM PROPERTY Unedited CRA Tags 110.6(1) Principal Issues: Whether the land owned by a taxpayer is considered to be "qualified farm property"? ...
Conference
26 May 2005 Roundtable, 2005-0164671C6 - Retroactive changes in assessing practice
However, it should be noted that these decisions were made in light of extenuating circumstances and should be considered the exception rather than the rule. ...
Technical Interpretation - Internal
10 August 1998 Internal T.I. E9817257 - NON-ARM'S LENGTH, PARTNERSHIP
Since all parties to the transaction are related, it is our view that the partnership would be considered to have acquired the property from a person with whom it was not dealing at arm’s length. for Director Resources, Partnerships and Trusts Division Income Tax Rulings and Interpretations Division Policy and Legislation Branch ...
Technical Interpretation - External
10 March 1997 External T.I. 9705915 - INDIANS - INVESTMENT INCOME
The exemption with respect to investment income was considered in the Recalma case, wherein it was concluded that income earned in the economic mainstream is not connected to a reserve. ...
Ministerial Letter
16 February 1997 Ministerial Letter 9641038 - POST-DATED CHEQUES
In rare cases, when a post-dated cheque is accepted in absolute settlement of a debt, such as when both parties agree that the post-dated cheque settles the debt, the value of the post-dated cheque is considered to be income at the time it is received. ...
Technical Interpretation - External
8 January 1997 External T.I. 9642045 - SECURITIES LENDING
Our position as stated in the letter is as follows: "In our view, a partnership is not to be considered a "person" or a "taxpayer" for the purposes of section 260 of the Act and its partners would not be accorded the treatment provided for in section 260 of the Act. ...
Technical Interpretation - External
12 June 1997 External T.I. 9708145 - HOME BUYERS' PLAN 90 DAYS RRSP PREMIUM
Position: No Reasons: Subparagraph 146(5)(a)(iv.1) prohibits a deduction for a premium considered to be withdrawn as an eligible amount within 90 days. 5-970814 XXXXXXXXXX Franklyn S. ...