Search - considered
Results 391 - 400 of 403 for considered
Ministerial Correspondence
28 May 1991 Ministerial Correspondence 911064 F - Death of a Taxpayer and Disposition of Capital Property
On the other hand, a taxpayer may be considered to be in the business of farming if a profit can reasonably be expected from the raising and exhibiting of horses. ...
Ministerial Correspondence
4 September 1990 Ministerial Correspondence 901304 F - Japanese Citizens Working and Living in Canada
As we mentioned to you in our discussions, we are of the view that a person's intention to return to Japan after an extended stay in Canada should not preclude the person from being considered factually resident in Canada. ...
Ministerial Correspondence
14 August 1991 Ministerial Correspondence 911724 F - At-Risk Rules
Consequently, the general partner of such a partnership will not be considered to be a limited partner by virtue of paragraph 96(2.4)(b) of the Act. ...
Ministerial Correspondence
20 July 1989 Ministerial Correspondence 58084 F - Carved Out Property/Farm Out
In addition, the farmee will be considered to have an amount receivable for the purposes of subsection 66(12.1) of the Act, equal to the fair market value of the depreciable property so received. ...
Ministerial Correspondence
10 July 1991 Ministerial Correspondence 91042-4 F - Interest Deductibility
It was therefore considered appropriate to review RCT's position on interest deductibility with respect to these topics. ... As part of our analysis concerning Issue 1, we also, considered whether interest deductibility by a debtor under subparagraph 20(1)(c)(i) on indebtedness attributable to borrowed money would be affected should the lender dispose of the indebtedness to a third party. ...
Ministerial Correspondence
14 July 2011 Ministerial Correspondence 2010-0386191M4 - Canadian withholding taxes
A service business is considered to be carried on at the place or places where the services are performed. ...
Ministerial Correspondence
2 July 2010 Ministerial Correspondence 2010-0359971M4 - social assistance
If the assistance offered by the XXXXXXXXXX under the Home Sharing Program is provided on the basis of need, and at least one of the financial tests above is applied to you or to your daughter, then the payment you receive can be considered social assistance for the purposes of paragraph 56(1)(u) and paragraph 110(1)(f) of the Act. ...
Ministerial Correspondence
19 March 2007 Ministerial Correspondence 2007-0225871M4 - FILING DEADLINE FOR T3 SLIPS
Once one partner files the T5013 return, all partners are considered to have filed the return. ...
Ministerial Correspondence
19 November 1999 Ministerial Correspondence 1999-0010440 - Exempt surplus - compensatory payments
In the situation described in the above question, if Holdco made a compensatory payment to Lossco for the use of its loss, under clause 5907(1.1)(b)(ii)(B) of the Regulations the amount of the payment would be considered a refund to Lossco for the year of the loss and deducted from Lossco's exempt deficit at that time. ...
Ministerial Correspondence
6 March 1991 Ministerial Correspondence 903374 F - Deferred Annuity Plan
Accordingly, a situation in which a taxpayer withdraws some or all of his funds from an annuity in a lump sum could be considered to be a surrender and, therefore, a disposition of all or a part of his interest in the annuity as the case may be. ...