Search - considered

The Department of Finance noted that there are principle-based arguments in favour of an amendment to the Act to permit the non-taxable portion of a trust's capital gains to be added to a corporate beneficiary's capital dividend account, but other issues need to be considered concurrently. ...

A loss is considered to reduce the SI of the corporation at the time it is incurred because the assets used to fund the loss are no longer on hand and thus can no longer contribute to the value of the corporation's shares. 3 The SI and SIOH attaching to the shares of Parentco is nil even though Parentco is in a position to receive a $100 safe dividend from Subco2. ...

However, where the employee's total vehicle expenses for employment-related activities in a year exceed the total travel allowance received in that year, the allowance may be considered unreasonable. ...

We have not been provided with sufficient details to determine whether the $XXXXXXXXXX payment would be considered a retiring allowance as defined in subsection 248(1) of the Act. ...

As Germany is generally considered a high tax jurisdiction, it may be difficult for the taxpayer to utilize the carry-forward of credits. ...

The representatives conclude that their strategy was based on their opinion that XXXXXXXXXX rights as a beneficiary can be considered separately from her duties as an Executor. ...

It states the following: "A provision for anticipated taxes is considered a reserve and, accordingly, is added to capital unless a notice of assessment has been issued with respect to that amount, in which case the assessment establishes the tax liability which would only be included in the capital tax base pursuant to paragraph 181.2(3)(f) to the extent that the amount of the liability has been outstanding for more than 365 days before the end of the year. ...

Paragraph 12 of IT-218R states: Vacant land that is capital property used by its owner for the purpose of gaining or producing income will be considered to have been converted to inventory at the earlier of (a) the time when the owner commences or causes the commencement of improvements thereto with a view to selling it, and (b) the time of making application to the relevant authority for approval of a plan to subdivide the land into lots for sale, provided that the taxpayer proceeds with the development of the subdivision. ...

Paragraph 6 states that, where the duties are expected to provide the individual with continuous employment beyond two years, as determined at the outset, those duties are generally not considered to be of a temporary nature. ...

Generally a court order would be considered to be “made” when the order is rendered. ...