Search - considered

. … [T]he CRA does not intend to generally substitute its judgment of what would be considered a reasonable amount where the taxpayers have made a good faith attempt to do so …. ...

Consequently, when a dividend that gives rise to the dividend refund is paid by the payer corporation, that portion of the dividend [that is sufficient to give rise to the dividend refund would be considered to be paid out of the safe income of the payer corporation.... ...

Since for the purposes of the Act an estate is considered to be a trust, the estate may therefore acquire an annuity as annuitant as long as the minor child is the only one, prior to their death, beneficially interested in the amounts payable under the annuity. ...

In each case, would such land be considered to be an asset used principally in an active business “carried on” by the corporation for purposes of the definition of "qualified small business corporation share"? ...

In the course of a general discussion of a scenario in which, because of the remoteness of certain customers, the employer would pay $30.00 per day worked in situations where employees could not return home within 36 hours, CCRA indicated that: The phrase "the duties performed by the taxpayer were of a temporary nature” was considered to refer to the duration of the work performed by the employee in question and not to the expected duration of the project undertaken by the employer. ...

In finding that Opco’s safe income on hand at the safe income determination time (June 29) should be reduced by the s. 111(5.1) write-down, CCRA referred to the statement in the 1988 Robert Read paper that: If it is reasonable to expect that any of the income earned or realized in a stub period will be offset by losses in the remainder of the year, then the calculation of the safe income on hand for the stub period should reflect the anticipated losses, since that income could not reasonably be considered to be reflected in the inherent gain in the shares. ...

“[I]f an employee voluntarily adheres to the telework arrangement proposed by their employer, the employee is considered to have an obligation to use part of their home to perform the duties of employment and to pay certain expenses relating to this space devoted to working from home as long as the employee and the employer enter into a formal telework agreement.” ...

. … In our opinion, for the purposes of calculating the CEC of Amalco in Situations 1 and 2 described above, it should be considered that there is a continuation of the calculation of the CEC of Portfolioco and Subco in Amalco. ...

The DR amount of $74,500 for the 2000 TY would be considered to have been refunded to Bco, pursuant to subsection 160.1(4), as it was applied against Bco's Part I tax payable for the year. ...

For the purposes of the credit (OETC) under s. 122.3(1), are the periods of stay abroad considered to be interrupted by the leave periods: where it is expected that: (1) they will return within a short period of time (usually two weeks) to work abroad on the same contract or on a new contract entered into by Canco; (2) where, upon the return to Canada, there is no planned foreign assignment (although the employee in fact will return abroad after that so that the cumulative length of the stays abroad, including holiday periods in Canada, will exceed 6 months); or with the variation on Situations 1 and 2 (so as to constitute Situations 3 and 4) that Canco issues a termination notice to the casual employee at the end of each stay abroad? ...