Search - considered

In these cases, the advance income tax ruling will be considered invalid and the CRA will not be bound by it. ... Response 3 To date, there have been seventeen referrals considered by the Committee. ... In 9044-2807 Québec Inc., the Federal Court of Appeal considered a situation involving three corporations owned by members of a family. ...

Where it is considered that a part of a debt is collectible and a part is not, a portion only of the debt may be viewed as a bad debt. 6. ... If a debt is merely doubtful of collection, it should not be claimed as a bad debt but should be considered for purposes of a reserve for doubtful debts. ... Any subsequent disposition of the property so received in exchange is considered to be the disposition of a capital property and is subject to the rules relating to capital gains and capital losses. ...

In these cases, the advance income tax ruling will be considered invalid and the CRA will not be bound by it. ... Response 3 To date, there have been seventeen referrals considered by the Committee. ... In 9044-2807 Québec Inc., the Federal Court of Appeal considered a situation involving three corporations owned by members of a family. ...

These properties will not be considered to have been acquired for purposes of calculating the accelerated CCA claim until they are available for use. ¶ 6. ... An offshore drilling platform of the "jack-up" type that stands on the seabed is not considered to be a vessel. ... Similarly, court decisions subsequent to the date of the IT should be considered when determining the relevancy of the comments in the IT. ...

The "all or substantially all" test referred to above is considered to be met if 90% of the employment duties are performed outside Canada. ... See the current version of IT-270, Foreign Tax Credit, for factors that may be considered in the determination of where particular types of businesses are carried on. ... If these activities are carried out regularly over a period of time, then the entity may be considered to carry on business with respect to those activities. ...

The "all or substantially all" test referred to above is considered to be met if 90% of the employment duties are performed outside Canada. ... See the current version of IT-270, Foreign Tax Credit, for factors that may be considered in the determination of where particular types of businesses are carried on. ... If these activities are carried out regularly over a period of time, then the entity may be considered to carry on business with respect to those activities. ...

The "all or substantially all" test referred to above is considered to be met if 90% of the employment duties are performed outside Canada. ... See the current version of IT-270, Foreign Tax Credit, for factors that may be considered in the determination of where particular types of businesses are carried on. ... If these activities are carried out regularly over a period of time, then the entity may be considered to carry on business with respect to those activities. ...

The term "in Canada" as used in 2 above will be considered to include the territorial sea of Canada, as defined in the Territorial Seas and Fishing Zones Act and the overlying airspace. ... This means that any equipment and personnel that are engaged under, upon or above the seas while carrying out any of the activities described in paragraph 255(b) in, upon or over any submarine areas described in paragraph 255(a) will be considered to be in Canada while so engaged. ... However, ships not engaged directly or indirectly in any activity described in paragraph 255(b) will not be considered to be in Canada for the purpose of 5 below, while merely traversing an area of the sea which is by virtue of section 255, determined to be in Canada for purposes of that section only. 5. ...

A taxpayer is not considered to have a right or thing in respect of a registered retirement savings plan, whether matured or not, if the taxpayer was, until death, the annuitant thereunder. ... Similarly, a taxpayer is not considered to have a right or thing in respect of a registered retirement income fund. 4. ... Unless subsection 70(6.1) applies, the deceased taxpayer will be considered to have been paid immediately before death, pursuant to subsection 70(5.4), all amounts held for or on behalf of the taxpayer in the taxpayer's NISA Fund No. 2. ...

A gift by an individual of a life insurance policy (both "whole life" and "term life") to a registered charity or any other donee described in any of paragraphs (a) to (g) of the definition of "total charitable gifts" in subsection 118.1(1) of the Income Tax Act is considered to be a charitable gift within the context of that subsection. ... If the premiums on the policy are paid directly to the insurance company at the request of, or with the concurrence of, the donee, this action is considered to be constructive payment of a donation to the donee and therefore a charitable gift for the purposes of the Act. ... For the purpose of subsection 148(1), it is considered that the donor's proceeds of disposition of the life insurance policy will be the value of the policy at the time of the assignment (see 3 above). ...