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In these situations, the residence of this other person may be considered to be the determining factor for the trust, regardless of any contrary provisions in the trust agreement. ...

In this respect, a debenture issued prior to January 1, 2010, but modified on or after that date will be considered issued on or after January 1, 2010. ...

Change in Domestic Position In contrast to the OECD Commentary, the long-standing view of the CRA on determining the location of services to which a stock option benefit relates was such that the benefit was generally considered to be attributable to services rendered in the year of grant, unless there was compelling evidence to suggest that some other period was more appropriate. ...

Where the Second Affiliate and Third Affiliate are fiscally transparent, the shareholders or members of the Second Affiliate would still be considered to be subject to income taxation on the income earned by the Third Affiliate notwithstanding that the Second Affiliate incurred interest expense on the loan used to acquire the shares of the Third Affiliate. ...

In Technical Interpretation 2015-0596311I7, CRA concluded that a Segway is not sufficiently similar to a standing wheelchair to be considered a “wheelchair” within the ordinary meaning of the term and therefore the cost will not be an eligible expense under paragraph 118.2(2)(i) of the Income Tax Act (“Act”). ...

In the historical technical notes that accompany subsection 147.4(1), the Department of Finance provides the following example of RPP annuity acquisition that is not considered to satisfy the conditions for the deeming rules in subsection 147.4(1) to apply: On retirement, Catherine, a member of a defined benefit RPP is entitled to an indexed pension of $20,000 per year. ...

To make this determination, a number of indicators were considered. We checked the number of hits each Bulletin received over the past several years on the CRA website. ...

Position: Question of fact- depends on the terms of the trust and the nature and extent of the trustee's discretion as to whether an amount in considered "payable" Reasons: Meaning of payable- 104(24) for purposes of subsection 104(6) QUESTION #4- TAXATION OF INCOME OF TESTAMENTARY SPOUSAL TRUST AFTER DEATH OF SPOUSE BENEFICIARY Let's assume the following facts: 1. ...

Where a donation is made by will, it is considered to be a donation of the deceased. ...

In the context of the conversion of shares from one class to another, the determination of whether subsection 70(6) could apply is dependent on whether the shares held by the deceased taxpayer at his or her death were considered to have been transferred or distributed to and vested indefeasibly in the spousal trust prior to the share conversion. ...