Search - considered

Principal Issues: Are payments under the Ontario Workplace Safety and Insurance Act (formerly Workers' Compensation Act) considered to be a pension for purposes of the Act? ... Each claim is considered and treated separately and benefits are based on each individual situation. ... We recognize that certain benefits provided under the WSIA may also be considered payments that qualify as a pension benefit under paragraph 56(1)(a) of the Act. ...

Is a USLLC considered to be resident for treaty purposes to receive treaty benefits? ... Where the situs of mind, management and control is considered to be located elsewhere, USLLC may be considered resident in a different country. ... Where a distribution is considered a dividend and the recipient is considered a qualifying person pursuant to Article XXIX-A of the Treaty, Article X, if applicable, should limit the US tax withheld on the distribution to 15%. ...

3) Where a computer is purchased before the beginning of a sabbatical leave can the purchase of the computer be considered an allowable research expense? ... More than 30 days in one place will likely be considered sojourning. Reasons: 5(1), 56(1)(o) and IT-75R4 2005-011892 XXXXXXXXXX Luisa A. ...

It is our view, however, that where an asset, such as cash temporarily surplus to the needs of a business, is invested in short-term income producing investments, those investments may be considered to be used in the business. ... Rather such funds would be considered as permanently set aside for investment or non-qualified uses (i.e., uses other than for active business). ... In the Department's view, cash and near cash assets held to offset the non- current portion of long term liabilities will not generally be considered to be used in the business. ...

Principal Issues: Whether insurance proceeds received as a result of the destruction by fire of a business asset are considered an active business asset. Position TAKEN: Such insurance proceeds will generally be considered to be active business assets. ... In the Department's view, cash and near cash assets held to offset the non-current portion of long term liabilities will not generally be considered to be used in the business. ...

The rare circumstance where individuals insured under the policy actually share in the dividend or refund is now covered, and explained in the Technical Notes. 2.For an amount to be considered paid under the policy it must first become payable under its terms, then when the obligation is discharged in one form or another the amount would be considered paid. 961230 XXXXXXXXXX J.A. ... As a starting point in determining whether an amount is considered paid under the policy, it should first be determined whether the amount was payable under the terms of the policy. ... In our view, the amounts will be considered paid to the policyholder and to the extent that the account is accessed by employees, it will be considered distributed to individuals insured under the policy. ...

Principal Issues: Is prefabrication of log homes (but not erection of log homes) considered construction and thus excluded from the M&P credit? Position: probably not considered construction Reasons: The Company is apparently not involved in the construction of the log homes only the supply of building materials- since the company is not involved in the construction of log homes the activity (preparing of log home components) would not be considered construction. ... Based on the limited information you provided, it would appear that the Company's activities of processing lumber for direct sale and the preparing of log home components could be considered M&P activities. ...

While, in these circumstances, the sub-leasing revenue would be considered from the operation of ships, in any case where the sub-time chartering activity constitutes a separate business the revenue therefrom would not be considered to be from the operation of ships. ... Income from shipbroking will not be considered income from the operation of ships. ... Interpretation Bulletins IT-290, IT-371 and IT-400 outline some of the criteria that should be considered when determining which of a corporation's businesses should be considered its principal business. ...

Principal Issues: Would land owned by a partnership be considered QFP. ... The requirement is generally considered to have been met when the person is actively engaged in the management and/or day-to-day activities of the farming business. ... Similarly, real property used in a father and son farm operation may be considered qualified farm property provided all the other requirements of the definition are met. ...

Is the piece which is ready to operate considered to be available for use? ... Is the equipment in the second group considered available for use? 3.      ... Under the fifth scenario you asked if the computer or the software are considered to be available for use? ...