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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 - Adventure or Concern in the Nature of Trade

Where these phrases are used in the Act, a determination is made based on the degree of activity and each situation must be considered in the light of its own particular facts. 4. In determining whether a particular transaction is an adventure or concern in the nature of trade the Courts have emphasized that all the circumstances of the transaction must be considered and that no single criterion can be formulated. ...
Archived CRA website

ARCHIVED - Income of Deceased Persons -- Periodic Payments and Investment Tax Credit

However, if the taxpayer also had on hand a matured investment (such as a matured Treasury Bill or uncashed matured bond interest coupons) at the date of death, any interest that was owing to the deceased taxpayer on the matured investment immediately before the date of death would be considered a right or thing for the purposes of subsection 70(2) to the extent the amount was not included or required to be included in the deceased's income for the year or a preceding year. ... Similarly, court decisions subsequent to the date of the IT should be considered when determining the relevancy of the comments in the IT. ...
Archived CRA website

ARCHIVED - Investigation of Site

For purposes of paragraph 20(1)(dd), it is immaterial whether the site is land owned by the taxpayer or land being considered for possible purchase by him. ... The following types of expenditures are not considered to be incurred for the purpose of investigating the suitability of a site for a proposed building or other structure and thus do not qualify for a deduction under paragraph 20(1)(dd): (a) Expenses incurred to persuade potential tenants to lease space in a proposed building or to induce investors to invest in it. ...
Archived CRA website

ARCHIVED - Sale of Accounts Receivable

Where 90% of the assets of the business carried on in Canada are sold, all or substantially all of the assets of such business will be considered sold. ... If the purchase is on capital account and any of the purchased accounts receivable is considered uncollectible at the end of a taxation year ending subsequent to the purchase, the purchaser is deemed, by paragraph 50(1)(a), to have disposed of it at that time, giving rise to a capital loss. ...
Archived CRA website

ARCHIVED - Guidelines for the cancellation and waiver of interest and penalties

It also explains how taxpayers or employers can make a request to cancel or waive interest and penalties for years dating back to 1985, and describes the information required for such requests to be considered. 3. ... The following factors will be considered when determining whether or not the Department will cancel or waive interest or penalties: (a) whether or not the taxpayer or employer has a history of compliance with tax obligations; (b) whether or not the taxpayer or employer has knowingly allowed a balance to exist upon which arrears interest has accrued; (c) whether or not the taxpayer or employer has exercised a reasonable amount of care and has not been negligent or careless in conducting their affairs under the self-assessment system; (d) whether or not the taxpayer or employer has acted quickly to remedy any delay or omission. ...
Archived CRA website

ARCHIVED - Registered Charities Newsletter - Spring 2001 - No. 10 - Spring 2001

A political activity is considered partisan if it involves direct or indirect support of, or opposition to, a political party or candidate for public office. ... Newsletter No. 7, Summer 1998, and Interpretation Bulletin IT-110R3, Gifts and Official Donation Receipts, explain that fund-raising golf tournaments are considered to be 'like events'. ...
Archived CRA website

ARCHIVED - Business Investment Losses

For the purposes of determining a business investment loss, a corporation that was a small business corporation at any time in the 12 months before the disposition of the share or debt, as the case may be, will be considered to be a small business corporation. ... If the debt is owed (except as discussed in ¶ 5 above) by a Canadian-controlled private corporation (see ¶ 4 above) or the share is a share of a small business corporation, the loss will be considered a business investment loss. ... In such a case, if paragraph 50(1)(a) applies to the debt or the loan, and the other requirements outlined in ¶ 3 above are met, the capital loss will be considered a business investment loss. ¶  15. ...
Archived CRA website

ARCHIVED - Registered Charities Newsletter No. 22 - Spring 2005

Purposes that are unlawful are considered impossible (for example, if they require discrimination). ... See Registered Charities Newsletter No.18 for information on factors considered in determining fair market value. ... If there is an advantage, should the rules of split-receipting apply so that only part of the donation may be considered a gift? ...
Archived CRA website

ARCHIVED - Employees Profit Sharing Plans - Payments Computed by Reference to Profits

The latter are generally considered "employee benefit plans" as discussed in the current version of IT-502, Employee Benefit Plans and Employee Trusts. 8. ... If an employer pays the administration fees to the trustee relating to an EPSP, they will be considered to be contributions to an EPSP, which are required to be allocated to the members of the plan. ... Accordingly, the employer payments would not be considered contributions to an EPSP. ...

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