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Administrative Policy summary

84 C.R. - Q.33 -- summary under Paragraph 104(15)(b)

.- Q.33-- summary under Paragraph 104(15)(b) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(15)- Paragraph 104(15)(b) An alternate beneficiary who has succeeded to the income rights of a deceased discretionary beneficiary will be considered to be a discretionary beneficiary unless under the trust deed he has acquired a fixed right to a share of the accumulating income of the trust. ...
Administrative Policy summary

84 C.R. - Q.35 -- summary under Section 114

.- Q.35-- summary under Section 114 Summary Under Tax Topics- Income Tax Act- Section 114 A non-resident who only occasionally visits Canada to perform directorship duties will not thereby be considered to be employed in Canada throughout the period after he left Canada. ...
Administrative Policy summary

Income Tax Technical News, No. 7, 21 February 1996 (cancelled) -- summary under Subsection 249(4)

Income Tax Technical News, No. 7, 21 February 1996 (cancelled)-- summary under Subsection 249(4) Summary Under Tax Topics- Income Tax Act- Section 249- Subsection 249(4) Discussion of when shareholders of a closely-held corporation are considered to be acting in concert or otherwise to represent a group. ...
Administrative Policy summary

September 1991 Memorandum (Tax Window, No. 9, p. 23, ¶1457) -- summary under Subsection 2(1)

September 1991 Memorandum (Tax Window, No. 9, p. 23, ¶1457)-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) A trust generally will be considered to reside on an Indian reserve if the trustee or the majority of the trustees who manage or control the trust's assets reside on the reserve. ...
Administrative Policy summary

84 C.R. - Q.17 -- summary under Subsection 212(1)

Thus, unless there is an amount at the non-resident's disposal, no amount will be considered to be "credited". ...
Administrative Policy summary

88 C.R. - Q.26 -- summary under Salary Deferral Arrangement

.- Q.26-- summary under Salary Deferral Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement if on a specified date under a phantom stock plan the employee is only entitled to receive the increase in the value of the underlying phantom share, the plan generally will not be considered a salary deferral arrangement. ...
Administrative Policy summary

84 C.R. - Q.13 -- summary under Payment & Receipt

.- Q.13-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Under an unfunded deferred compensation plan, constructive receipt is considered to occur in situations where an amount is credited to an employee's account, set apart for the employee, or is otherwise available to the employee without being subject to any restriction concerning its use. ...
Administrative Policy summary

88 C.R. - F.Q.24 -- summary under Paragraph 12(1)(c)

.- F.Q.24-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) Where a parent provides an interest-free loan to a child, and the child gives the parent a gift which compensates him for the lost interest income, such gift is considered to have been received "as, on account or in lieu of payment of, or in satisfaction of", interest. ...
Administrative Policy summary

IT-259R3 "Exchanges of Property" -- summary under Subsection 44(5)

IT-259R3 "Exchanges of Property"-- summary under Subsection 44(5) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(5) "A taxpayer who changes from one business category to another but continues to deal in the same product will normally be considered to be in a 'similar business'". ...
Administrative Policy summary

80 C.R. - Q.26 -- summary under Paragraph 56(1)(d)

.- Q.26-- summary under Paragraph 56(1)(d) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(d) Where payments for damages that have been awarded by a court or resolved in an out-of-court settlement, in respect of personal injuries or death, are paid on a periodic basis, the payments will not be considered to be annuity payments for the purposes of ss.56(1)(d) and 60(a). ...

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