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Archived CRA website

ARCHIVED - Prepayments of rents

The payment of an amount for the right to assume, from the payee, an existing lease whose rental is below current market values is considered a premium. 4. In determining whether a payment is a premium or is prepaid rent or contains an element of both, each case must be considered in the context of the factual circumstances of the transaction. ...
Archived CRA website

ARCHIVED - Meaning of private health services plan [1988 and subsequent taxation years]

The consideration given by the employee is considered to be the employee's covenants as found in the collective agreement or in the contract of service. 8. Medical and hospital insurance plans offered by Blue Cross and various life insurers, for example, are considered private health services plans within the meaning of subsection 248(1). ...
Archived CRA website

ARCHIVED - Payments based on production or use

In such a situation the proceeds will be on account of capital and if there is a reasonable expectation at the time of disposition of the property that the conditions will be met, then the disposition is treated in the ordinary manner, and the original maximum amount is considered to be the sale price of the property. ... IT-426, "Shares Sold Subject to an Earnout Agreement", will be considered appropriate only in the circumstances referred to therein. ...
Archived CRA website

ARCHIVED - Special release: Attribution of Trust Income to Settlor (Revision to it369r dated March 12, 1990)

A genuine loan to a trust would not by itself be considered to result in property being "held" by the trust under one or more of these conditions (i.e., would not by itself result in the application of subsection 75(2)), if the loan is outside and independent of the terms of the trust. For a discussion on when a loan can be considered genuine, see the current version of IT-258, Transfer of Property to a Spouse and IT-260, Transfer of Property to a Minor. ...
Archived CRA website

ARCHIVED - Taxable Canadian property - Interests in and options on real property and shares

Any of the above would be considered an option on a share where it contains an irrevocable offer in respect of a specified period of time to acquire a share. 4. ... For example, if a non-resident owns 15% of the shares of a public corporation and has an interest in or option on another 15% of the same class of shares, the 25% requirement is met and any gain on the disposition of one or more of the corporation's shares, or on the disposition of the interest or option, will be considered to be a gain on the disposition of taxable Canadian property. ...
Archived CRA website

ARCHIVED - General Income Tax and Benefit Guide - 2000

If you had a same-sex partner who met these conditions in 1998, 1999, or 2000, you can choose to be considered a common-law partner starting from that year: 2000- To have the choice apply for 2000, in the Identification area of your returns for 2000, both of you have to check the "Living common law" box, provide each other's name and SIN, and indicate if the other was self-employed in 2000. ... Province or territory of residence Enter the province or territory where you lived or of which you were considered to be a factual resident on December 31, 2000. ...
Archived CRA website

ARCHIVED - Registered Charities Newsletter - Summer 1998 - No.7 - Summer 1998

Just as a "like event" that is combined with a chance to win a prize or a draw is not considered a "like event", similarly a "like event" that is combined with an auction is also not considered a "like event". ...
Archived CRA website

ARCHIVED - Expenses of Issuing or Selling Shares, Units in a Trust, Interests in a Partnership or Syndicate and Expenses of Borrowing Money

It is a question of fact whether a particular fee is reasonably considered to relate solely to the year. For example, a one-time fee related to a loan with a term longer than one year, such as a loan-structuring fee or loan-placement fee, is not reasonably considered to relate only to the year in which the loan was made. ... In that situation, the expense will normally be considered to be incurred in the course of the issuance. ...
Archived CRA website

ARCHIVED - 5013-G General Income Tax and Benefit Guide for Non-Residents and Deemed Residents of Canada - 2004 - Electing under section 217

Generally, the non-resident withholding tax is considered your final tax liability on the income. ... If you send us your return after the due date, your election will not be considered valid. The 23% non-resident withholding tax will be considered the final tax liability. ...
Archived CRA website

ARCHIVED - Electing under section 217

Generally, the non-resident withholding tax is considered your final tax liability on the income. ... If you send us your return after the due date, your election will not be considered valid. The 23% non-resident withholding tax will be considered the final tax liability. ...

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