Search - considered

After noting that under a joint tenancy, “the joint tenants have concurrent ownership and possession of the same property,” CRA stated: [W]here two or more joint owners of a share of a corporation are considered one shareholder under relevant corporate law or are entitled to jointly receive any dividend paid on the share by the corporation, the joint owners of the share will generally be counted as one shareholder for purposes of paragraph 130.1(6)(d) …. ...

For the purposes of the Act, in the absence of a provision similar to the definition in subsection 18(3), a building or other structure affixed to land would generally be considered as part of the land. ...

18 November 2021 External T.I. 2021-0917841E5 F- Traitement fiscal d’un revenu d’une emphytéose-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition the granting of an emphyteusis is a part disposition of property rather than a lease In 2013-0487791E5 F, CRA reversed its position in 2012-0472101E5 F and indicated that it now considered that the entering into of an emphyteutic lease represents a part disposition of property rather than something analogous to the entering into of a common law lease. ...

26 October 2021 External T.I. 2019-0800111E5 F- Psychothérapeutes du Québec, professionnels de la-- summary under Subsection 118.4(2) Summary Under Tax Topics- Income Tax Act- Section 118.4- Subsection 118.4(2) Quebec psychotherapists added to list of authorized medical practitioners CRA indicated that it “will shortly be adding” the words “psychotherapist legally authorized" to its list of Authorized medical practitioners for the purposes of the medical expense tax credit, so that “expenses incurred for psychotherapy services rendered by psychotherapists who hold a psychotherapy permit issued by the Ordre des psychologues du Québec will now be considered medical expenses … for purposes of the medical expense tax credit.” ...

In finding that such commuted value was to be included at the time of the transfer in the individual’s income pursuant to s. 56(1)(a)(i), CRA stated that “the Individual is considered to have constructively received the benefit on the basis that, by virtue of the Transfer, the benefit has been set apart for the Individual.” ...

X, did not provide services or property, directly or indirectly, in any manner whatever, to the other, then on that basis neither CCPC would be considered to have earned income described in s. ...

CRA stated: Aviation headsets would not be considered tools. … IT-422, [para. 2] … provides that in order for an asset to be a tool, it must be designed to create a physical change in something or be used as an instrument of measurement or manipulation. … In addition, paragraph 8(6.1)(d) of the Act specifically excludes electronic communication devices as eligible tools. ...

CRA considered that such meal expenses could be deducted pursuant to s. 8(1)(h) assuming inter alia that, as required by s. 8(4), the pilot was away from the home city on each trip for at least 12 consecutive hours. ...

After indicating that such conversion would not cause a share disposition if no shares were cancelled and the rights of the shareholders were not substantively altered, CRA went on to indicate that if there otherwise was a disposition, s. 51 would not apply, stating: … 2013-0473771E5 … confirmed that a person who has a membership interest in a non-share capital corporation would not be considered to hold a share in that corporation. ...

(a) of the definition of “designated investment service” in s. 115.2(1) relevantly excluded only investment management and advice, CRA indicated that mere administrative services performed by the Manager would not by themselves cause the limited partners to be considered to be carrying on business in Canada (and similarly regarding any administrative services of the GP.) ...