Search - considered

Background In 1984 the Review Committee considered the above issue (d.S. 5021-5) and adopted the position that a deceased person and his estate are not non-arm's length for purpose of section 84.1. ...

A "retirement plan" is generally considered to include an RRSP and a RRIF. ...

However, the memorandum also went on to state that where the compensation is considered to be contingent for financial statement purposes, it would be difficult to argue that the compensation is not also contingent for tax purposes. ...

Paragraph 7 of Interpreta- tion Bulletin IT-50R states, in part, that the owner of a building under construction is considered to have acquired the building at any particular time to the extent of the construction costs incurred by him to that time or the progress billings received by him to that time, as the case may be. ...

While as your example Suggests the application of section 79 to a guarantor in peculiar circumstances could provide for unusual results we would prefer to review a specific situation before suggesting that an amendment should be considered. ...

HAV 6752-1 We are writing in response to your memorandum of January 15, 1988, wherein you requested our opinion as to whether or not representations should be made to the Department of Finance regarding a possible amendment to Regulation 5700 in order that the costs of the Wright Linear Pump could be considered prescribed equipment for purposes of subparagraph 110(1)(c)(xii). ...

RESPONSE This question was answered at the 1986 tax conference.1 It is the view of the Department that, for purposes of section 85 of the Act, an interest in a partnership is not considered to be an interest in its underlying assets. ...

Ernie Wheeler, you asked whether "tax exempt" income earned by a status Indian is considered "earned income" for purposes of calculating the amount eligible for deduction as an RRSP contribution. ...

Options held by persons dealing at arm's length with the particular non-resident person would not be considered to have been exercised. ...

Generally, it is our view that phantom stock plans will be considered to be "salary deferral arrangements" as that term is defined in the Act. ...