Search - considered

Instead, as the employer, partnership, charity or public institution would be considered to be the recipient of the supply, the usual rules for determining whether that person was eligible to claim ITCs or rebates would apply. ...

(iii) A final bona fide repayment would not be considered part of a series for the purpose of s. 212.3(10)(c)(i), so that a particular amount owing by a subject corporation to a CRIC which arose in the ordinary course of its business of the CRIC would meet the exception if its final bona fide repayment was made within 180 days after the day on which it became owing. ...

In situations where some proportion of shares is being replaced with borrowed money, only the capital of those shares, computed on a pro-rata basis, would be considered to be replaced with the borrowed money. ...

Where the terms of an exchangeable share permit the taxpayer to exchange its shares with the issuer for shares of another company, would ancillary rights enabling such taxpayer to put its shares to another person for the shares of the other company in the event the issuer is unable to effect the exchange be considered to be an agreement for purposes of the DFA definition? ...

Where a lower amount of Part XIII tax would be due when compared to the amount previously remitted, a refund may be considered if requested within two years from the end of the calendar year in which the withholding tax was initially remitted, as per s. 227(6) (para. 17). ...

If the CRA accepts a disclosure as having met the conditions set out in this policy, it will be considered a valid disclosure and the taxpayer will not be charged penalties or prosecuted with respect to the disclosure. ...

However, we will not permit revisions when, in the Department's view, the main purpose of the amended election is:...retroactive tax planning, such as taking advantage of losses or tax credits not considered when the election was originally filed. ...

Has it considered pre-acquisition PUC planning more recently? Consider the following: Foreign Parent subscribes for shares of its wholly-owned Canadian acquisition company (CanAc) having full paid-up capital. ...

In this case, it is unlikely that the period could be considered to end later than the commencement of the negotiations in February of year 1. ...

., 10 or more residential units, the entire complex is considered to meet the expected one-year occupancy test if substantially all of the units (90% or more) meet that test. ...