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Ministerial Correspondence

26 February 2001 Ministerial Correspondence 2001-0068924 - Trust Assessment Court Challenge

The tax policy issues raised in the Auditor General's 1995 report were considered by the House of Commons Standing Committee on Finance in its report released in September 1996. ...
Ministerial Correspondence

7 November 2018 Ministerial Correspondence 2018-0780421M4 - Life insurance - refund of premium benefit

Under the Income Tax Act, the savings accumulated in a life insurance policy are generally taxable unless the policy is considered exempt and the savings are paid to a named beneficiary as part of a death benefit. ...
Ministerial Correspondence

26 November 2018 Ministerial Correspondence 2018-0776571M4 - Fraudulent investment - recourse

In your request for a second administrative review, you should explain in detail the reasons why you disagree with the original decision and include any new relevant information not considered. ...
Ministerial Correspondence

7 December 1989 Ministerial Correspondence 59084 F - Preferred Beneficiary Election under Testamentary Spouse Trust

Where a subsection 104(13.1) designation is made and a beneficiary makes, or is considered to have made, a payment to the trustee to enable the trustee to pay the tax liability of the trust caused by the designation, the following results would occur: (a)     Where the trust is a testamentary trust, the payment would represent a contribution to the trust for the purposes of subparagraph 108(1)(i)(ii) of the Act.  ...
Ministerial Correspondence

28 May 1991 Ministerial Correspondence 910724 F - Definition of "Qualified Farm Property"

You inquired if the property, would be considered to be Qualified Farm Property under each scenario outlined above.  ...
Ministerial Correspondence

25 April 1991 Ministerial Correspondence 910354 F - Retiring Allowance

Such payments of salary would be considered remuneration from employment rather than a retiring allowance unless the employment benefits in question are of no significance to the employee. ...
Ministerial Correspondence

19 March 1990 Ministerial Correspondence 59494 F - Acquisition of Control

Generally, for purposes of subsections 111(5) and 249(4) of the Act, a group of persons will be considered to have acquired control of a corporation where there is evidence that they have a common link or interest or that they act together to control the corporation.  ...
Ministerial Correspondence

28 February 1990 Ministerial Correspondence 74704 F - Registered Pension Plan - Internal Cost of Operation Paid from RPP Funds

., implicit or explicit) by which the actuary reflects the fact that such costs were considered is immaterial in and of itself. 3.      ...
Ministerial Correspondence

23 March 1990 Ministerial Correspondence 90M03244 F - Tax Executive Institute's Questions

Question 7- TERM PREFERRED SHARES Department's position (a)     "Sufficient common connections or business interests" is one of the factors to be considered.  ...
Ministerial Correspondence

11 July 1989 Ministerial Correspondence 58104 F - Income Tax Treatment of Payments to Employees on Leave

We have taken the position that where, in an arm's length situation, a long term employee is discharged or laid-off without any prospect of being rehired, and the employee receives a payment from the employer in recognition of long service or in respect of the loss of his office such payment would be considered to be a retiring allowance. ...

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