Search - considered

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. ...

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. ...

Therefore, as no portion of the $1,000 taxable income would be considered to be earned in a province, the amount determined pursuant to Part IV of the Regulations is 0 for the purposes of item B of section 8600 of the Regulations. 3. ...

As a result, these amounts would be considered to be "investment income" as defined in subsection 110.6(1) that would offset the amount of the benefit included in "investment expense" as defined in subsection 110.6(1) of the Act. ...

Also, the “redemption” of the 100 Special B shares of Tool Co. (1988) Ltd. on June 1, 1989 could be considered as part of the series of transactions or events that included the transactions which occurred on July 1, 1988. ...

While we do not give opinion on the operation of the tax law of Barbados it is evident from the comments of the competent authority of Barbados that management fees paid to a non-resident person by a person resident in Barbados is considered to be income derived from Barbados and thereby subject to tax at source in Barbados. ...

" However, an amount is considered earned and is not in respect of services not rendered if the taxpayer's right to the amount is under no restriction, contractual or otherwise, as to its disposition, use and enjoyment, or the taxpayer's right to the amount is absolute and unconditional. ...

The payment by the employer is not viewed as a “contribution” by the employer to the plan and, hence, paragraph 6(1)(f) does not apply to subject to tax in the employee's hands, at any time, any benefits received by him pursuant to the plan as no employer contributions are considered to have been made. ...

Where the simple interest accrued on a loan with a one year term is replaced with a new borrowing having as its principal amount the aggregate of the accrued interest and original funds advanced, it is our view that it is a question of fact whether the accrued interest on the first loan will be considered to be paid on granting the second and subsequent loans. ...

Once a plan is selected and the setup costs or fees charged by the plan administrators in respect of the particular plan are paid by the employer then the plan would not be considered an employee-pay-all plan. ...