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Under subsection 274(3), an avoidance transaction is a transaction that alone, or as part of a series of transactions, would result directly or indirectly in a tax benefit were it not for section 274, unless the transaction can reasonably be considered to have been undertaken or arranged primarily for bona fide purposes other than to obtain the tax benefit. 7. Subsection 274(4) provides that subsection 274(2) does not apply in respect of a transaction where it may reasonably be considered that the transaction would not result, directly or indirectly, in a misuse of the provisions of Part IX or in an abuse of Part IX (other than section 274) read as a whole. In this respect, tax planning or transactions that are carried out for purposes other than obtaining tax benefits but which minimize the payment of tax, when compared to other transactions which would achieve the same purpose but which would result in higher tax liability, may not be considered to be avoidance transactions. 8. ...

The service of a driver generally will not be considered to be a freight transportation service. ... ABC is considered the invoicing carrier and charges the applicable GST/HST to the shipper. ...

In addition, the manner in which Company A operates is considered to be further evidence of its purpose. ... The pass/fail element is considered to be met where there is real potential for individuals to be held back if they are not competent in the course material. 42. ... The pass/fail element is considered to be met where there is real potential for students to be held back in the event that they are not competent in the course material. 46. ...

In certain circumstances, separately ticketed domestic services are considered to form part of a continuous international journey. ... Note: For administrative purposes, when a transfer to another conveyance is required to complete the continuous journey, a period of 24 hours will be considered reasonable within which to make this connection. ... When a transfer to another conveyance is required to complete the continuous journey, a period of 24 hours is considered reasonable within which to make the connection. ...

"Related persons" are not considered to deal with each other at arm's length. ... Business expenses – costs that are considered reasonable that your business incurs to operate and earn income. ... Deemed – a legal term used for something that is considered something else in a specific situation. ...

"Related persons" are not considered to deal with each other at arm's length. ... Business expenses – costs that are considered reasonable that your business incurs to operate and earn income. ... Deemed – a legal term used for something that is considered something else in a specific situation. ...

Here is a list of common types of organizations that participate in the program and would be considered eligible. ... Additionally, if an organization is part of or is a department of a municipal or provincial government, they would still be considered eligible for the grant. ... Organizations that require donations, advertise fees for service, or have a mandatory payment form for the tax clinic would be considered ineligible. ...

Sample pro forma- Declaration of Trust This pro forma declaration of trust is to be considered as a template that can be used by prospective RDSP issuers to develop their own declaration of trust. ... This plan will not be considered registered unless the issuer notifies the Specified minister of this plan's existence without delay. ... Other than for the purposes of this section and for the purposes of section 7A, a specified RDSP payment and an accumulated income payment from a registered education savings plan are not considered contributions to this plan. ...

IAD efforts were focused on four areas that were considered at risk for the 2005-2006 fiscal year. ... The audit work focused on areas that were considered at risk for the 2005-2006 fiscal year. ... Also considered for this is cash on hand, which represents cash receipts received in the old fiscal year but deposited in the new fiscal year. ...

Downward adjustments are also considered by the Competent Authority Services Division in certain cases. 8. ... For tax years subject to a transfer pricing audit in progress, the CRA will review downward adjustment requests to determine if the circumstances are such that it would be considered appropriate that the adjustments be made. 15. ... This may be considered base erosion and profit shifting and retroactive tax planning and may not be considered appropriate in the opinion of the Minister. ...