Search - considered

Accordingly, lump sum payments or proceeds received by a corporation under the terms of a disability policy would be considered proceeds from the disposition of a capital property and therefore subject to the capital gains provisions. ...

If, as suggested in your memorandum, the employer and the employee/shareholder entered into an agreement whereby the employee/shareholder accepted an obligation of the corporation as payment of the remuneration, the remuneration would be considered to have been paid upon that acceptance. ...

In some instances, a conversion right is severable from a convertible security and can be traded separately in which cases the conversion right is considered to be a separate property (hereunder called "conversion option"). ...

If, for instance, the payment can be considered to be a "management or administration fee or charge" to which subsection 212(4) of the Act does not apply or an amount to which subsection 214(15) applies, it could be subject to withholding tax. ...

It indicates that where an individual enters Canada and establishes residential ties in Canada he will generally be considered to have become a resident of Canada for tax purposes on the date he entered Canada. ...

Legal costs which were essential to incur in respect of and directly relate to the conduct of an action for wrongful dismissal will not, to the extent that such costs were actually incurred by a taxpayer, be considered to form part of a retiring allowance. ...

XXXX We have considered the information set out in your letter and regret that we must conclude that the expense in question is not eligible for deduction. ...

The 1979 letter to 24(1) referred to in your memorandum indicates that the views set out therein were not to be considered as a precedent and that the matter was under review by the Department. ...

Only then would the plan be considered an employee-pay-all plan. We enclose a copy of Interpretation Bulletin IT-428 and draw your attention to paragraphs 16 to 21 therein. ...

In our opinion, generally a genuine loan to a trust or an unconditional bona fide sale of income-producing property to a trust would not, in and by itself, be considered to result in property being held in the trust on any of the conditions listed in paragraphs 75(2)(a) and (b), assuming that the loan or the sale is outside or independent of the terms of the trust. ...