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Technical Interpretation - Internal

4 November 1996 Internal T.I. 9630056 - refundable ITC and loss carryback

In our view, if the conditions are considered met, the onus would be placed on the Department to justify a refusal to accede to the reassessment request. ...
Technical Interpretation - Internal

12 December 1996 Internal T.I. 9629217 - NON-CAPITAL LOSS & DIVISION C DEDUCTIONS

As a result, the amount can be considered "deducted" so that it can, in turn, be used to preserve the amount of the non-capital loss which would otherwise be reduced by the taxable capital gain included in income. ...
Technical Interpretation - Internal

10 March 1993 Internal T.I. 9236857 F - Health and Welfare Trusts

The trust in question is currently known as the XXXXXXXXXX Following our review of the trust agreement submitted at that time, we set out a number of deficiencies in our December 9, 1991 memorandum which, we believed, required remedial action before the Trust could be considered to be a health and welfare trust described in IT-85R2. ...
Technical Interpretation - Internal

4 October 1993 Internal T.I. 9319827 F - Auto Lease Cancellation Payment

In order for an amount to be considered an "actual lease charge", it must be payable pursuant to the lease and relate to the use of the vehicle by the lessee. ...
Technical Interpretation - Internal

19 November 1993 Internal T.I. 9316317 F - Private Health Services Plan

Special foods or beverages are considered to be "medicaments, or other preparations or substances" as that phrase is used in paragraph 118.2(2)(n) which requires that two other conditions be met in order for those costs to be eligible; (1) that they be prescribed by a medical practitioner and (2) that the item be purchased from a licensed pharmacist who has recorded the prescription in his prescription record. ...
Technical Interpretation - Internal

31 January 1994 Internal T.I. 9328977 F - CCA Class of Building Used in Peat Processing

Since harvesting would not ordinarily be considered to be "mining" without this specific inclusion, and since there is no reference in this definition to the processing of peat, those activities would therefore only appear to fall within the definition of mining if they can be said to fall within the definition of "harvesting". ...
Technical Interpretation - Internal

29 March 1995 Internal T.I. 9419557 - FEDERAL SALES TAX REFUND

(a) Paragraph 12(1)(x) applies in that the FST refund can be considered an amount received by XXXXXXXXXX, in the course of earning income from a business, from a government, as a reimbursement in respect of an expense or outlay. ...
Technical Interpretation - Internal

1 May 1995 Internal T.I. 9510657 - DISCOUNTS ON BONDS

For an amount to be considered interest, the position of the Department is that it must meet all three of the following criteria: (1) it must represent compensation for the use of a principal sum or a right to a principal sum; (2) it must be calculated by reference to a principal sum or a right to a principal sum; and (3) it must be calculated on a daily accrual basis. ...
Technical Interpretation - Internal

10 May 1995 Internal T.I. 9511696 - LIF PAYMENTS TO NON-RESIDENT

Note that a payment out of a LIF which is not a RRIF may be entitled to the withholding tax treatment accorded to a periodic pension payment under an income tax treaty if it is a pension payment and not excluded from the definition of a "periodic pension payment" in the ITCIA. 4.Since the maximum payout under such plans is set by each province, it may or may not be possible for a particular recipient to withdraw an amount large enough to be considered a lump sum amount by Revenue Canada. ...
Technical Interpretation - Internal

6 June 1995 Internal T.I. 9502287 - HOME RENOVATIONS AS MEDICAL EXPENSES

In this case, therefore, to the extent that the addition to the house was considered necessary in order for the patient to be mobile and functional within the dwelling, reasonable costs incurred to construct the addition would be eligible for the medical expense tax credit. ...

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