Search - considered

To the best of your client's and your knowledge, none of the issues involved in this ruling application is being considered by a Tax Services Office or a Taxation Centre in connection with any tax return already filed and none of the issues is under objection. ... It is considered that the Options to be granted to the Employees will provide the Employees with additional incentives to further the growth and development of the Company. ...

Robertson's address to the 1981 Canadian Tax Foundation states at page 88: "Dividends paid in the period covered by the computation will be considered to first reduce the amount of the safe income even if such dividends were paid at a time in the period covered by the computation when such a dividend would not have been considered to be a safe dividend if subsection 55(2) applied to the transaction. ...

B is used to provide the 24-hour care and is considered to be the principal place of residence of the handicapped adults. • Mrs. C provides some part-time care in her principal residence, but her residence is not considered the principal place of residence of the handicapped adults. • ACo receives funding from the Persons with Developmental Disabilities organization under the Foster Child Care Act for the following services: (i) room and board for the handicapped adults at an hourly rate; (ii) time spent accompanying the handicapped adults to community functions and businesses calculated on an hourly basis; and (iii) providing 24-hour home care under the “Support Home Program”. ...

PRINCIPAL ISSUES: Whether an amount paid by a foreign affiliate could be considered "relevant in computing the liability for income taxes" for the purposes of 95(2)(a)(ii) if a deduction is allowed under foreign tax law resulting in an increased foreign tax credit carryover but the liability for income tax in the year the amount is deducted, is unchanged. ... You question whether in the above circumstances the Allocated Interest paid by Holco would be considered "relevant in computing the liability for income taxes" of the Group in Country X for the purposes of clause 95(2)(a)(ii)(D)(V) of the Act. ...

REASONS FOR POSITION TAKEN: The terms of the settlement are considered to be consistent with the Department's position set out in paragraphs 3 and 5 of IT-365R2. ... You have advised and you confirm, to the best of your knowledge, that none of the issues involved in this ruling request is being considered by a Tax Services office or a Tax Centre in connection with a tax return already filed and none of the issues is under objection. ...

Brokers' Opinion XXX Toronto District Office Opinion In the view of Source Deductions, Toronto District Office, the payment could be considered interest for purposes of paragraph 212(1)(b). ... The Department has taken the position that in a typical case a loan of securities is a disposition for tax purposes and that a broker which is a borrower is considered to have acquired the securities at the time the so-called loan is made. ...

Would the following be considered key criteria? (a) The advertiser's intent as measured by the words and images of the message and the audience it appears designed to influence. ... Each particular advertisement must be considered on its own merits rather than as part of a campaign. ...

In the event he is not a factual resident, he is certainly a deemed resident (eg. 250(1)(e) as a spouse of a deemed resident or 250(1)(c) in the case where he is still considered an officer or servant of Canada while on leave of absence- which I believe is a possibility). 2. ... The concept of "ordinarily resident" here should not affect a deemed resident because under the ITA such a person would be considered a factual resident (s.s. 250(3)). ...

To be considered as being in respect of SR&ED (carried on in Canada) for purposes of subsection 37(1), an expenditure must be one which is described in either clause 37(7)(c)(ii)(A) or (B) of the Act. ... Where SR&ED results in a saleable product, the costs of producing that product may be considered to be other than SR&ED expenditures. ...

the written evidence authorizing the applicant to act for the taxpayer or in the advance ruling request should be a statement whether any of the issues involved in the ruling request are, to the best of the taxpayer's knowledge, being considered by a District Office and/or Taxation Centre in connection with a tax return already filed, or if any of the issues are under objection. ... As you were informed in our August 11 correspondence, under these circumstances, the Department's policy is to presume that the petitioner is not proceeding with the request for the advance income tax rulings and that the request is considered withdrawn. ...