Search - considered

Clause 24(1) of the Plan provides that the interest earned will be paid out to a participant on December 31st of each year in which the participant is a member of the Plan so long as the Plan is considered by Revenue Canada Taxation to be an investment contract. ...

Reasonability of travel outside Canada Our Directorate has considered many situations where we opined that reasonable travel expenses to obtain medical services outside Canada were likely to qualify for the METC, provided all the requirements under paragraphs 118.2(2)(g) or 118.2(2)(h) were met. ...

A partnership is generally not considered to be a taxpayer and does not generally have a liability under Part I of the Act. ...

4 April 2024 External T.I. 2024-1004651E5- QZETMA: Battery Separators Unedited CRA Tags Regulation 5202(a) Principal Issues: Are battery separators manufactured for battery cells for zero-emission vehicles considered to be "integral components of the powertrain of the zero-emission vehicle, including batteries or fuel cells" for purposes of clause 5202(a)(i)(K) of the definition of qualified zero-emission technology manufacturing activities in the Regulations? ...

Note The central management and control of an organization is usually considered to be exercised by the group that performs the function of a board of directors of the organization. ...

Principal Issues: Whether, as a result of paragraph 128.1(1)(b) of the Act, there would be an income inclusion in computing income of Canco on the immigration of CFA1 that could potentially result in taxation of the same amount of the capital gain accrued on the shares of CFA2 in the hands of Canco and CFA1, if the shares of CFA2 are not considered excluded property. ...

Reasons: The financial assistance provided in the particular situation should be considered first and foremost as amounts received in respect of an outlay or expense (i.e. interest) and consequently should not be considered as an assistance received in respect of or for the acquisition of, depreciable property. ...

Accordingly, when a debt is forgiven, it is generally considered a disposition to the creditor. ...

2 December 2011 External T.I. 2011-0424446E5- Interaction of Subsections 249(3.1) and 249(4) Unedited CRA Tags 125(1); 125(7); 256(9); 249(4); 251(5)(b); 249(3.1) Principal Issues: Whether, in the circumstances where a sale of the shares of the capital stock of a Canadian-controlled private corporation ("CCPC") to a non-resident purchaser results in a change of CCPC status and a change of control on the same day, the hypothetical corporation would be considered to be a CCPC throughout the taxation year such that the small business deduction provisions of subsection 125(1) would apply? ...

Raisons: (1) Wording of the provision. (2) Given the fact that the transitional reserve is temporary and that it may reasonably be considered that the qualifying transitional income on which the reserve is based results in an increase in value of the shares. ...