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Technical Interpretation - Internal

23 December 2013 Internal T.I. 2013-0514701I7 - Bitcoins

Responses Provided: Buying and Selling Goods or Services in Exchange for Bitcoins Income Tax Implications Virtual currencies, such as Bitcoins, are not considered to be a currency issued by a government of a country, such as American dollars. ...
Technical Interpretation - Internal

24 October 2012 Internal T.I. 2012-0462411I7 - Payment in Lieu of Severance - Indian

In Williams, the SCC considered the location of the employment that gave rise to the qualification of the unemployment insurance benefits to be a strong factor connecting the benefits to the reserve. ...
Technical Interpretation - Internal

10 May 2013 Internal T.I. 2012-0464901I7 - 93(2), 93(2.01) - Share substituted

Issue You have asked our views on whether the shares of Forco3 could be considered to be shares for which the shares of Forco1 were substituted under the meaning of this expression as it is used in the stop loss rules of paragraph 93(2)? ...
Technical Interpretation - Internal

19 November 2013 Internal T.I. 2013-0499021I7 - Distribution of property by a trust

Similarly, in document 2013-0488381E5 the sentence "In order to retire the $30 debt, the portion of the fair market value of the property required to settle the debt is $30" must be considered. ...
Technical Interpretation - Internal

15 April 2013 Internal T.I. 2012-0471161I7 F - Avantage imposable - Taxable Benefit

Toutefois, il y a un avantage imposable pour l'employé qui a quitté son emploi pour une autre raison que la retraite. c) Le paragraphe 32 du IT-470R(consolidé); position de longue date. a) and b) Generally, in accordance with the definitions of the terms "employee" and "office" contained in subsection 248(1), the directors of a corporation are considered employees of the company. ...
Technical Interpretation - Internal

24 May 2013 Internal T.I. 2013-0476361I7 - RESP - Replacement of Beneficiary

Under paragraph 204.9(4)(a) of the Act, if an individual (the "new beneficiary") becomes a beneficiary under an existing RESP and replaces an existing beneficiary (the "former beneficiary") who ceases to be a beneficiary of the plan, all of the contributions into the RESP for the former beneficiary are also considered to be contributions for the new beneficiary when determining whether or not an "excess amount" exists for the new beneficiary, unless either of the conditions in subparagraphs 204.9(4)(b)(i) or (ii) of the Act apply. ...
Technical Interpretation - Internal

22 March 2013 Internal T.I. 2012-0470371I7 - Indian - XXXXXXXXXX

Generally, when the office is located on a reserve, the employment duties are considered to be performed on a reserve. ...
Technical Interpretation - Internal

7 August 2015 Internal T.I. 2015-0585011I7 - Osteopaths & naturopaths in Quebec

Section 26 of the Professional Code provides that "The members of an order shall not be granted the exclusive right to practise a profession except by an Act…" In our view, a regulated health professional recognized under the Professional Code, who is acting within the scope of their professional training, would be considered a medical practitioner for the purposes of subsection 118.4(2) of the Income Tax Act. ...
Technical Interpretation - Internal

23 April 2015 Internal T.I. 2014-0562271I7 - Amending a partnership return - limitation period

Consequently, once the income or loss of a partnership return is determined, it is considered equivalent to having been assessed for the purposes of subsection 152(4). ...
Technical Interpretation - Internal

31 March 2015 Internal T.I. 2014-0555921I7 - Early Childhood Worker Grant Program

The relevant types of income that we have considered are employment income, scholarship or bursary income and government-sponsored earning supplement. ...

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