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Technical Interpretation - Internal
17 January 1995 Internal T.I. 9333197 F - Part Year Resident
Concerning section 216 of the Act, if an election is made, for the year of departure, for rental income received after the date of departure, these amounts of rental income would not be considered "income earned in the year in a province". ...
Technical Interpretation - Internal
12 October 1994 Internal T.I. 9425396 - DEDUCTION LIMITS AND FOREIGN PROPERTY RULES FOR AN RRSP
I would add that guaranteed investment certificates are included in the definition of qualified investments for self-directed RRSPs and therefore must be considered in the calculation of the foreign property limit. ...
Technical Interpretation - Internal
24 January 1995 Internal T.I. 9423867 - RRSP REPORTING PAYOUTS ON DEATH
Paragraph 6 of IT500 discusses when a legal representative is considered to be entitled to receive amounts for the benefit of a spouse. ...
Technical Interpretation - Internal
5 January 1995 Internal T.I. 9433456 - DISABILITY PAYMENTS
In case of a degenerative illness which continues to afflict the taxpayer, the bulletin states that the "event" is considered to be the onset of the disease however much later the incapacity occurs. ...
Technical Interpretation - Internal
16 November 1994 Internal T.I. 9414677 - FILM RIGHTS
Paragraphs 14 through 17 of IT-477 discusses circumstances which would cause a licence to be considered to be renewable or extended beyond the initial period. ...
Technical Interpretation - Internal
8 November 1994 Internal T.I. 9426387 - TRANSFER OF PRE 1972 PROPERTY TO A TRUST
In a letter dated December 3, 1975, to XXXXXXXXXX the Department stated: "It is correct that before the words "or events" were added to subsection 26(5) ITAR in 1974, the Department agreed that the devolution of property on death of a taxpayer could be considered something other than a transaction to which the concept of a "non-arm's length" transaction applies. ...
Technical Interpretation - Internal
1 April 1996 Internal T.I. 9607716 - TRANSFER FROM PARENT TO CHILD, MEANING OF SUPPORT
In particular, you ask whether a parent or child in receipt of social assistance could be considered to be dependant on another family member for support. ...
Technical Interpretation - Internal
22 April 1996 Internal T.I. 9608007 - STRUCTURED SETTLEMENTS
As described in the advance ruling provided by this Directorate dated June 17, 1988 this individual became entitled to receive three payments pursuant to the damages settlement which were to be respectively received by the Plaintiff or his estate on XXXXXXXXXX an arrangement considered to be a "structured settlement", described in paragraph 5 of IT-365R2, with the result that the three periodic payments would be non-taxable. ...
Technical Interpretation - Internal
17 June 1996 Internal T.I. 9607477 - CANNOT CREATE LOSS IN A H&W TRUST
Nevertheless, in response to your question concerning coverage for XXXXXXXXXX who are not considered employees, XXXXXXXXXX, one of the trustees of the plan, confirmed that, while special arrangements might be possible to provide coverage for a self-employed individual, a separate assessment would be required to determine the level of contributions required for such coverage. ...
Technical Interpretation - Internal
8 July 1996 Internal T.I. 9617717 - LEVERAGED LEASES AND PREPAID PENSION - PART I.3
In particular, should reserves be examined on an individual basis or is it the net amount of all reserves which should be considered for Part I.3 purposes? ...