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Administrative Policy summary
90 C.R. - Q26 -- summary under Subsection 186(4)
.- Q26-- summary under Subsection 186(4) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(4) A corporate beneficiary of a trust will not be considered for purposes of s. 186(4)(b) to own shares held by the trust notwithstanding that the trust has made a designation under s. 104(19) in respect of taxable dividends paid on the shares. ...
Administrative Policy summary
IT-464R, para. 8 -- summary under Paragraph 69(1)(c)
IT-464R, para. 8-- summary under Paragraph 69(1)(c) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(c) "When a tenant makes improvements and alterations to leased property and subsequently abandons them, they are not considered to have been acquired by the landlord as a gift, bequest or inheritance under paragraph 69(1)(c). ...
Administrative Policy summary
IT-468R "Management or Administration Fees Paid to Non-residents" (Archived) 29 December 1999 -- summary under Article 7
IT-468R "Management or Administration Fees Paid to Non-residents" (Archived) 29 December 1999-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 Where the treaty does not contain a specific article on management or administration fees, such fees paid to the non-resident will, to the extent they are reasonable, be considered to be covered by the business profits article. ...
Administrative Policy summary
88 C.R. - "Automobile Rules" - "Employee Benefits" -- summary under Paragraph 6(1)(a)
.- "Automobile Rules"- "Employee Benefits"-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) The cost of employer-paid repairs resulting from an accident suffered by the employee is considered to form part of the total operating costs of the automobile for the purpose of calculating the operating cost benefit under s. 6(1)(a)(iii). ...
Administrative Policy summary
IC 75-6R "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada" -- summary under Article 14
IC 75-6R "Required Withholding from Amounts Paid to Non-Resident Persons Performing Services in Canada"-- summary under Article 14 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 14 Where an individual is present in Canada for a period not exceeding 60 days and is not entering Canada on a recurring basis, the individual will not be considered to have a fixed base in Canada. ...
Administrative Policy summary
Income Tax Technical News No. 14, 9 December 1998 -- summary under Timing
Income Tax Technical News No. 14, 9 December 1998-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing RC will accept (at the choice of the mutual fund) either the realization method or the mark-to-market method for recognizing income on futures, forwards and options that are considered to be held on income account. ...
Administrative Policy summary
19 September 1991 Memorandum (Tax Window, No. 9, p. 12, ¶1463) -- summary under Paragraph 122.2(2)(b)
19 September 1991 Memorandum (Tax Window, No. 9, p. 12, ¶1463)-- summary under Paragraph 122.2(2)(b) Summary Under Tax Topics- Income Tax Act- Section 122.2- Paragraph 122.2(2)(b) One spouse will not be considered as a supporting person in respect of the other if one of the individuals is terminally ill and resides at a hospital on a permanent basis. ...
Administrative Policy summary
1994 A.P.F.F. Round Table, Q. 44 -- summary under Article 5
Round Table, Q. 44-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 "The Department usually considers that, where the Canadian activities of a foreign business are carried on through an organized and structured sales force, the sales force may represent for the non-resident sufficient substantial presence in Canada to be considered a permanent place of business and thus a permanent establishment. ...
Administrative Policy summary
P-013 - "Accounts Receivable for Consumption in the Course of Commercial Activities" -- summary under Subsection 167(1)
P-013- "Accounts Receivable for Consumption in the Course of Commercial Activities"-- summary under Subsection 167(1) Summary Under Tax Topics- Excise Tax Act- Section 167- Subsection 167(1) Under the former version of s. 167(1), accounts receivable were not considered to be included in the determination of whether "all or substantially all" of the property was being transferred. ...
Administrative Policy summary
May 1999 CALU Conference No. 9908430 Q.10 -- summary under Paragraph 20(1)(e.2)
May 1999 CALU Conference No. 9908430 Q.10-- summary under Paragraph 20(1)(e.2) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e.2) The premiums under universal life insurance policy paid in a year are considered to be in respect of that year. ...