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Technical Interpretation - Internal

28 June 1994 Internal T.I. 9413047 - CLASSIFICATION OF CAPITAL LEASE PAYMENTS - COMPUTERS

(Even if the cost of certain of this equipment could so be considered to form the cost of another asset, as you have noted, this other equipment would have to meet the definition of "gas or oil well equipment" found in subsection 1104(2) of the Regulations in order to be included in paragraph (j) of Class 10). ...
Technical Interpretation - Internal

16 August 1994 Internal T.I. 9413957 - MEDICAL EXPENSE CREDIT AND OTHER PRESONAL CREDITS

For the grandson to be considered the grandmother's dependant pursuant to subsection 118(6) of the Act, he must be "dependent upon the individual for support"; not "wholly dependent upon the individual for support". ...
Technical Interpretation - Internal

10 November 1994 Internal T.I. 9421446 - REASSESSMENT TO REDUCE PENALTY UNDER FAIRNESS LEGISLAT

Please note that, while the comments which follow represent our considered opinion of the technical merits of the issue, the responsibility for determining the validity of any particular notice of objection rests with Appeals Branch. ...
Technical Interpretation - Internal

3 November 1994 Internal T.I. 9411717 - 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

23 March 1992 Internal T.I. 9205027 F - Valuation of Securities

In the present situation, any premium or discount incurred or received by the taxpayer would be considered to be an adjustment to the purchase price of the securities and calculated as such. ...
Technical Interpretation - Internal

26 June 1995 Internal T.I. 9509556 - MOVING EXPENSES

The non-exhaustive definition merely clarifies or extends the ordinary meaning....In some cases, however, the context or the legislative history will indicate that even a definition introduced by "includes" should be considered exhaustive. ...
Technical Interpretation - Internal

12 January 1996 Internal T.I. 9533047 - INTERIM ORDER FOR MAINTENANCE-"ARREARS" DEDUCTIBLE?

In other words, an amount may still be considered to be "payable on a periodic basis" even where the payment is made late and that late payment is one cheque which includes several periodic payments. ...
Technical Interpretation - Internal

14 May 2003 Internal T.I. 2003-0013467 - EDUCATION ASSISTANCE PAID TO INDIAN

When a scholarship or bursary is received by status Indians, paragraph 81(1)(a) of the Act and section 87 of the Indian Act may provide a tax exemption if the income is considered an Indian's personal property situated on a reserve. ...
Technical Interpretation - Internal

22 July 2003 Internal T.I. 2003-0024377 - ABIL-POST BANKRUPTCY RETURN

A debt is considered bad for the purpose of section 50 of the Act only when the whole amount is uncollectible or when a portion of it has been settled and the remainder is uncollectible. ...
Technical Interpretation - Internal

6 June 2003 Internal T.I. 2003-0183437 - Distributions from non-res trust

The trustee's payment of cash to reduce the principal outstanding on the Loan cannot be considered to be a distribution to a beneficiary. ...

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