Search - considered

You have asked us to comment on whether the rental income earned by the partnership would be considered income from a business, or property income. ... Our Comments It is a question of fact whether or not rental income is considered business income or property income. ... The tax treatment of rental income earned by a non-resident depends upon whether or not the rental operation is considered to be a business carried on in Canada. ...

Training costs would be considered to provide an enduring benefit to a taxpayer where they are incurred to obtain a new skill or qualification. ... You inquired whether the exam fees would be considered an "eligible capital expenditure" for your business. ... A number of intangible properties that are generally considered eligible capital expenditures are listed in IT-143R3, most notably goodwill. ...

Specifically you ask: 1) What type of accommodation is considered pertaining to travelling versus temporarily residing? ... 2) What is the maximum length of stay considered to pertain to travelling versus temporarily residing? ... Again the length of the stay must be considered together with the other relevant factors in order to reach a definitive conclusion. ...

Any location at or from which the employee regularly reports for work or performs the duties of employment is generally considered a regular place of employment. ... The travel from this job site to the employer's head office later in the day is considered travel for business purposes. The travel from the employer's head office to home at the end of the day is considered personal use of the motor vehicle. ...

Principal Issues: Would bonus interest payments paid directly into an RESP be considered contributions to the RESP by the subscriber for purposes of calculating the RESP annual limit for the year? ... Reasons: Where bonus interest on an investment held by an RESP is paid directly to the RESP, the bonus interest paid will not be considered a contribution made into the plan for purposes of sections146.1 and 204.9 of the Act. ... Where a debtor has a contractual obligation to pay bonus interest in respect of a qualified investment held by an RESP, the bonus interest will be considered a return on its investments and will not be considered a contribution made into the plan for purposes of sections146.1 and 204.9 of the Act. ...

If that activity would be considered farming as defined in subsection 248(1) of the Act. ... If that activity would be considered "farming". If these conditions are met, the portion of the land owned by your wife will also be considered "qualified farm property" since your father is also considered her parent by virtue of paragraph 252(2)(a) of the Act, which defines certain relationships for purposes of the Act. The land will be considered used principally in the course of farming if more than 50% of the total property is used in the business of farming. ...

Can the beneficiaries of the trust be considered to be members of the partnership (carrying on the business of the partnership), and if they are members, would they be considered to be related to the partnership for the purposes of subparagraph 110.6(14)(d) of the Act. Position: The beneficiaries of a trust would not be considered as members of the partnership where the trust owns an interest in the partnership. ... Accordingly, the beneficiary would not, on this basis alone, be considered a member of the partnership and as such, would not be related to the partnership under paragraph 110.6(14)(d) of the Act. ...

You have asked us if the corporation choose to submit its accounts for Canadian tax purposes with a fiscal period ending on December 31, will the inaugural fiscal period of the branch be considered May to December, thus requiring a proration of capital cost allowance, or instead be considered to be January to December, that coinciding with the fiscal period of the U.S. corporation for U.S. purposes? ... Our view is that the inaugural fiscal period of the U.S. corporation for Canadian tax purposes would be considered to be January to December if the corporation chooses that period and that the proration rule of capital cost allowance would not apply. 2. ... You have asked us if the corporation chooses to submit its accounts for Canadian tax purposes with a fiscal period ending on December 31, will the inaugural fiscal period of the branch be considered May to December, thus requiring a proration of capital cost allowance, or instead be considered to be January to December, that coinciding with the fiscal period of the U.S. corporation for U.S. purposes? ...

Whether a $XXXXXXXXXX gas allowance is considered a taxable benefit? 3. Whether employee rebate programs would be considered taxable benefits? ... As such these amounts would be considered taxable benefits under paragraph 6(1)(a). ...

A Band may be exempt from income tax on any income that it earns if the Band can be considered to be a public body performing a function of government or a Canadian municipality. Details regarding a particular Band and its functions would need to be considered to determine whether it may be considered to be exempt. ... In order for an organization to be considered resident on a reserve, the central management and control, or mind and management, over the organization would have to be exercised on a reserve. ...