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Conference
10 October 2008 Roundtable, 2008-0284941C6 F - GRIP Addition for 2006
Paragraph (c) provides the inclusion of a dividend received, which was deductible under subsection 112(1) of the ITA, paid by a connected corporation, within the meaning of subsection 186(4) of the ITA, to a certain extent considered to be "reasonable". ...
Conference
10 October 2008 Roundtable, 2008-0285281C6 F - Benefit conferred on a shareholder
If corporate property is made available for the personal use of a shareholder, a benefit under subsection 15(1) is generally considered to have been conferred on the shareholder. ...
Conference
9 October 2009 Roundtable, 2009-0329971C6 F - 18(3.1) - Dépenses liées à la construction
The accounting and bookkeeping expenses, the general and administrative expenses and the advertising expenses are normally not considered as costs relating to the construction of a building. ...
Conference
9 October 2009 Roundtable, 2009-0329991C6 F - Avis du ministre - Organisation à but non lucratif
We particularly refer you to question 3 under the link "Applying for registration" where the CRA specifies how an organization should state its purposes in its governing document to be considered charitable: "To qualify for registration, an organization must be established and operated exclusively for charitable purposes (also referred to as objects). ...
Conference
9 October 2009 Roundtable, 2009-0330131C6 F - Subsections 256(9) and (1.2)
9 October 2009 Roundtable, 2009-0330131C6 F- Subsections 256(9) and (1.2) Unedited CRA Tags 256(9) Principales Questions: In technical interpretation no. 9525315, the following fact situation was considered: On July 1, 1995 at 5:00 pm, a corporation ("Aco") sells to another corporation ("Bco") all of the issued and outstanding shares of the capital stock of an operating corporation ("Opco"). ...
Conference
9 December 2008 TEI Roundtable Q. 2, 2008-0300381C6 - Eligible Dividend Designations
Similarly, a notice in an annual or quarterly report that an eligible dividend has been paid is considered valid for that year or quarter, respectively. ...
Conference
10 October 2008 Roundtable, 2008-0285301C6 F - Impôts futurs-exploitation active d'une entreprise
In particular, for the purposes of the definitions of QSBCS and SBC and in order that an asset can be considered to be used in a business, in Ensite Limited v. ...
Conference
10 October 2008 Roundtable, 2008-0285041C6 F - Potential beneficiary of a trust
Z be considered to be a potential beneficiary of the trust, and consequently, will ZCO be associated with XCO pursuant to subparagraph 256(1.2)(f)(ii) of the ITA? ...
Conference
6 October 2006 Roundtable, 2006-0196191C6 F - Droit d'auteur -télécommunication
If we take into consideration the assumption put forward about the characterization of the payments Corporation B had made, these payments would be considered as royalties for the purpose of Article XII of the Convention. ...
Conference
6 October 2006 Roundtable, 2006-0196251C6 F - Rente assurée: Abri fiscal
However, in determining if the annuity is a tax shelter under subsection 237.1(1) of the ITA and if a prescribed benefit is expected to be received by a person, we are of the opinion that the demand loan could be considered to be a limited-recourse amount under subsection 143.2(7) of the ITA, and to be a prescribed benefit if it is established that no bona fide arrangements, evidenced in writing and made at the time the indebtedness arose for repayment by the debtor of the indebtedness and the related interest within a reasonable period not exceeding ten (10) years. ...