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First, a payment is deductible only to the extent that it can reasonably be considered to relate to an amount that, but for the repayment of the debt obligation, would have been paid as interest in the year. ...

5 June 2017 Internal T.I. 2014-0561391I7 F- Deemed security pursuant to 220(4.51) Unedited CRA Tags 220(4.5); 220(4.51) Principales Questions: Whether deemed security is considered to have been provided pursuant to subsection 220(4.51) in a situation where the total amount of tax for which security for departure tax must be provided pursuant to subsection 220(4.5) exceeds the amount of the deemed security? ...

M.N.R. [1995] 1 C.T.C. 196, 95 D.T.C. 5032, a similar argument was considered with respect to coming-into-force provisions for the 1993 amendment to subsection 220(3.1), which provided that the amended version was applicable "to the 1985 and subsequent taxation years. ...

Consequently, based on the limited information available to us, it is likely that the CSC Income would not be considered to be sufficiently connected to a reserve to be viewed as located on a reserve and would therefore be taxable. ...

Conditions for eligibility vary; but, generally require that any area of land so considered must be currently in active annual crop production since the year 2000, or currently in a rotation that contains row crops. ...

As a general rule, however, an allowance that is designed to cover an employee's "out-of-pocket" costs for the use of a motor vehicle during the course of performing the duties of employment is considered a reasonable allowance for purposes of paragraph 6(1)(b) of the Act. ...

You wanted to know whether an apprentice in either of the above noted trades would be considered an eligible apprentice for the purposes of the apprenticeship job creation tax credit. ...

We understand that it is considered to be a corporation for Canadian and US income tax purposes. ...

Section 30 of the Act effectively ensures the deductibility of certain costs where such costs would not otherwise be deductible but would generally be considered an integral part of the cost of land. ...

Normally, the training expenses of a non-arm's length employee would be considered reasonable when the training expenses are essentially the same as they would be if they were provided to an arm's length employee. ...