Search - considered

You have enclosed a copy of XXXX 1986 and have asked us to confirm that for the purposes of subparagraph 110(1)(d)(iii) of the Income Tax Act, the options granted to the employees under that plan would be considered to be granted on the starting date (July 1) of each annual offering by the corporation. ...

We also agree that if the annuity continues to be owned by the employer after the employee's retirement so that the annuity payments are made to the employer which in turn makes supplementary pension payments to the employee, the employee will not be considered to have constructively received the amount paid for the annuity. ...

We have reviewed and considered the comments raised in your letter, however, as the which is designed or adapted to carry more than the driver 2 passengers, it is our view that the supercab trucks are included in this definition. ...

In addition, this deduction is only allowed in computing a taxpayer's income from an office or employment It is our understanding that the Department has determined that the ministers of your Church are considered self-employed individuals and, accordingly, they would not be eligible for the clergyman's residence deduction described above. ...

The Regulations further provide in subsection 5000(1) that an interest in the pooled fund trust determined under subsection 5000(7) above will not be considered foreign property for the purposes of Part XI of the Income Tax Act if the trust did not acquire foreign property after June 30, 1971 or, if it did, at no time during the particular month did it hold foreign property the cost of which exceeded lO% of the cost of all property held by it. ...

Specifically, the practitioner wishes to know if the penalty is applicable to each property included in an election on the basis that where there are several properties listed on one election form each property is considered to be the subject of a separate election. ...

As we understand it, although the Board is considered to be a "Creature of Statute of the Province of British Columbia" it is "not deemed to be a Crown Corporation or Agent of the Crown". ...

The Department has no set guidelines as to which factors to use in different situations as all the circumstances must be considered in deciding each case. ...

As noted in paragraph 3 of IT-96R3, it is the Department's view that where a warrant is attached to a bond and the total issue price is equal to or less than the face value of the bond, no part of the issue price will be considered to be applicable to the Warrant. ...

.), they are considered separate legal entities in Canada. 2. For purposes of the Income Tax Act of Canada, the terms "person", "corporation" and "taxpayer" include those entitles incorporated under Part II of that Act. 3. ...