Search - considered

To be considered a replacement property, a particular property must meet all the requirements outlined in subsections 44(5) or 13(4.1) of the Act. ... However, in such situations, the specific facts must be considered to determine whether the particular property or properties purchased will be considered as a replacement property for the original property or properties.” ... It is a question of fact whether the Replacements would be considered a replacement property for purposes of subsections 44(1) and 13(4). ...

Reasons: The requirements under s. 8(1)(h.1) are not met since the work station would probably be considered their regular place of employment and the travel would be personal. ... When considering the deductibility of travel expenses or motor vehicle expenses under section 8 of the ITA, one of the factors that must be considered is whether the employee's place of work is considered to be his or her "regular place of employment". Generally, it is the view of the CRA that any location to which an employee regularly reports for work or performs the duties of the office or employment, is considered to be a regular place of employment. ...

An elk is not considered a bovine animal. 5-981536 XXXXXXXXXX Karen Power, CA (613) 957-8953 Attention: XXXXXXXXXX September 2, 1998 Dear Sirs: Re: “Specified Animals” We are writing in reply to your letter of May 13, 1998 requesting our views on whether or not elks would be considered “specified animals” for purposes of subsection 28(1.2) of the Income Tax Act (the “Act”). ... An elk is a member of the Cervidea family and is not considered a bovine animal. In our view, elks would not be considered “specified animals” for purposes of subsection 28(1.2) of the Act. ...

It is a question of fact as to whether a collection of individual policies can be considered to be issued pursuant to a common plan established by the employer to provide the applicable insurance for its employees. The fact that a particular policy was issued prior to the establishment of the plan would not necessarily cause the policy to be considered separate from the plan. However, just as paragraph 8 of Interpretation Bulletin IT-428 "Wage Loss Replacement Plans", a copy of which is enclosed, describes a situation where two separate plans may be considered as a common plan, an individual policy will only be considered to be issued pursuant to a common plan if all the employees covered by that plan are entitled to the same benefits under the respective policies and the ratio if any, by which the employer shares the premium with the employees is consistent for all members of that plan. ...

Considered a partial disposition of the underlying depreciable property. The remainder interest is considered a separate property in the hands of the acquiror. (2)No. ... The remainder interest would be considered to constitute a separate property to the holder. ...

In accordance with Interpretation Bulletin IT-392, the LLC is considered to have a capital stock consisting of 100 issued shares and each owner of a beneficial interest in the LLC is then considered to own a number of shares proportionate to his or her beneficial interest in the LLC. Each amount distributed on account of profits by the LLC to its owners will be considered dividends for purposes of the Act and the Regulations made thereunder. 3. If the LLC is treated as a partnership or disregarded entity for the purposes of the United States Internal Revenue Code (the "Code") such that the shareholders ("partners") rather than the LLC are liable to tax under the Code on the income of the LLC, it will not be considered resident in the United States under paragraph 1 of Article 4 of the Canada-U.S. ...

In accordance with Interpretation Bulletin IT-392, the LLC is considered to have a capital stock consisting of 100 issued shares and each owner of a beneficial interest in the LLC is then considered to own a number of shares proportionate to his or her beneficial interest in the LLC. Each amount distributed on account of profits by the LLC to its owners will be considered dividends for purposes of the Act and the Regulations made thereunder. 3. ... These comments are provided in accordance with the guidelines set out in paragraph 22 of Information Circular IC 70-6R4 dated January 29, 2001, issued by the Canada Customs and Revenue Agency (the "CCRA") and are not considered binding on the CCRA. ...

In accordance with Interpretation Bulletin IT-392, the LLC is considered to have a capital stock consisting of 100 issued shares and each owner of a beneficial interest in the LLC is then considered to own a number of shares proportionate to his or her beneficial interest in the LLC. Each amount distributed on account of profits by the LLC to its owners will be considered dividends for purposes of the Act and the Regulation made thereunder. 3. ... These comments are provided in accordance with the guidelines set out in paragraph 22 of Information Circular IC 70-6R4 dated January 29, 2001, issued by the Canada Customs and Revenue Agency (the "CCRA") and are not considered binding on the CCRA. ...

In accordance with Interpretation Bulletin IT-392, the LLC is considered to have a capital stock consisting of 100 issued shares and each owner of a beneficial interest in the LLC is then considered to own a number of shares proportionate to his or her beneficial interest in the LLC. Each amount distributed on account of profits by the LLC to its owners will be considered dividends for purposes of the Act and the Regulations made thereunder. 3. ... These comments are provided in accordance with the guidelines set out in paragraph 22 of IC 70-6R4 and are not considered binding on the CCRA. ...

However, at this time we are interested in obtaining an expert opinion on what the meaning of the word periodical is considered to be in the publication industry.  ... Therefore we are requesting your comments on whether the enclosed 24(1) described above would be considered to be a periodical publishing industry.  In addition, we are requesting a general definition or general guidelines as to the type of publication that would be considered a periodical. ...