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Technical Interpretation - External

25 May 2004 External T.I. 2003-0051241E5 - Foreign Business Income Tax Credit

Commonly accepted business or commercial practice should also be considered. ...
Technical Interpretation - External

30 June 2004 External T.I. 2004-0062121E5 - resident and n/r estate with resident and n/r bene

However, an estate (referred to in this letter as a trust) is generally considered to reside where the executor or other legal representative who manages or controls the assets of the estate resides. ...
Technical Interpretation - External

16 July 2004 External T.I. 2004-0070211E5 - expensed vs. capitalized

As indicated on page 13 of the Business and Professional Guide, the value or amount of the expense test should only be used if you cannot determine whether an expense is capital or current after having considered the tests described in the first three bullets under the elements of capital expenditure indicated above. ...
Technical Interpretation - External

6 December 2004 External T.I. 2004-0099571E5 - Test Wind Turbine - CRCE

In particular, we are not providing any confirmation as to the extent to which any particular equipment may be considered to be related to a particular wind-driven turbine or electrical generating equipment. ...
Technical Interpretation - External

10 March 2005 External T.I. 2005-0115671E5 - Immigrant trusts

Answer The non-resident trust may be considered to be holding assets that are indirectly transferred to the trust from you as paragraph 94(1)(b) looks to the person from whom the trust has acquired property, directly or indirectly in any manner whatsoever. ...
Technical Interpretation - External

27 March 2001 External T.I. 2001-0067745 - IN-TRUST ACCOUNTS FOR MINORS

Whether or not a particular arrangement involving an in-trust account is considered a trust at law is, as explained below, a question of fact. ...
Technical Interpretation - External

14 September 2001 External T.I. 2000-0027015 - Trusts and Farm Property Rollovers

However, where the Department is satisfied that a property is held in trust solely to carry out the terms of a will under which the ultimate and absolute ownership of that property is bequeathed to a particular individual and the trust arrangement is such that the individual's ownership rights cannot be defeated by any future event and no other person has any right whatsoever to an immediate or future benefit from that property or that trust, (emphasis mine) the property will be considered to vest indefeasibly in that individual. ...
Technical Interpretation - External

20 December 2001 External T.I. 2001-0097805 - PHSP

As requested, we have considered your questions and have provided general comments below. ...
Technical Interpretation - External

7 February 2002 External T.I. 2001-0109875 - US MEDICARE PLAN B

Interpretation Bulletin IT-339R2, Meaning of "Private Health Services Plan", describes the criteria that must be satisfied in order for a plan to be considered a PHSP. ...
Technical Interpretation - External

18 February 2002 External T.I. 2001-0107045 - PRINCIPAL RESIDENCE

When rent commences to be charged on a residence that was previously used as a personal residence, it is considered to be a change in use from personal use to income producing. ...

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