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Archived CRA website

ARCHIVED - Income of contractors

In less formal situations where no construction contract exists or where the terms of a contract do not require formal approval of progress billings by the purchaser's architect or engineer before payment, the amount thereof, net of holdbacks if any, will be considered to be receivable and includable in the contractor's income as of the date such billings are made. 4. ... In contrast to 7 above, a cost is not considered to have been incurred in the performance of a contract in the year and is not deductible in the year in accordance with the comments in 6 above when it is, for example, (a) the cost of materials that have been merely ordered for future delivery, (b) the cost of materials and supplies that are described in a contractor's inventory, as that term is defined in subsection 248(1), including those earmarked for a specific contract but not delivered to the job site, (c) a holdback withheld by a contractor from a subcontractor if the contractor's liability to the subcontractor in respect thereof has not been established by the issuance of a required certificate by an architect or engineer, or (d) the gross amount of a billing rendered by a subcontractor to a contractor that requires, but has not received, approval prior to payment. 9. ... Where a person obtains a contract and agrees to sell to another person the right to carry out or complete the contract, the amount received on the sale is regarded as being in lieu of the profits expected to be earned had the contract been carried out in full, and therefore the amount is considered to be income. ...
Archived CRA website

ARCHIVED - Dispositions of Cultural Property to Designated Canadian Institutions

However, if the taxpayer's legal representative applies in writing within that period to the Director of the local Revenue Canada tax services office, an extension of the period to what is considered reasonable in the circumstances may be granted. ¶ 5. ... If a gift is described in two or more of the categories of "total charitable gifts," "total Crown gifts," "total cultural gifts" or "total ecological gifts" made after February 27, 1995, it will be considered in the following order: a cultural gift, an ecological gift, a Crown gift, and a charitable gift. ¶ 8. ... The reader should, therefore, consider such comments in light of the relevant provisions of the law in force for the particular taxation year being considered, taking into account the effect of any relevant amendments to those provisions or relevant court decisions occurring after the date on which the comments were made. ...
Archived CRA website

ARCHIVED - General Income Tax and Benefit Guide - 2002

If you lived outside Canada on December 31, 2002, but maintained residential ties with Canada, you may be considered a factual resident of a province or territory. ... However, this may not apply if you were a factual resident who, under a tax treaty, is considered to be a resident of another country. ... Deemed resident- You are a deemed resident for tax purposes if you did not establish residential ties in Canada, but you stayed here for 183 days or more in 2002 and, under a tax treaty, you were not considered a resident of another country. ...
Archived CRA website

ARCHIVED - Income of contractors

In less formal situations where no construction contract exists or where the terms of a contract do not require formal approval of progress billings by the purchaser's architect or engineer before payment, the amount thereof, net of holdbacks if any, will be considered to be receivable and includable in the contractor's income as of the date such billings are made. 4. ... In contrast to 7 above, a cost is not considered to have been incurred in the performance of a contract in the year and is not deductible in the year in accordance with the comments in 6 above when it is, for example, (a) the cost of materials that have been merely ordered for future delivery, (b) the cost of materials and supplies that are described in a contractor's inventory, as that term is defined in subsection 248(1), including those earmarked for a specific contract but not delivered to the job site, (c) a holdback withheld by a contractor from a subcontractor if the contractor's liability to the subcontractor in respect thereof has not been established by the issuance of a required certificate by an architect or engineer, or (d) the gross amount of a billing rendered by a subcontractor to a contractor that requires, but has not received, approval prior to payment. 9. ... Where a person obtains a contract and agrees to sell to another person the right to carry out or complete the contract, the amount received on the sale is regarded as being in lieu of the profits expected to be earned had the contract been carried out in full, and therefore the amount is considered to be income. ...
Archived CRA website

ARCHIVED - Canada Council Grants

In addition, payments made for the purchase of works of art from a self-employed artist under the Art Bank program of the Council are not grants but are considered to be ordinary business income to the artist; accordingly, such payments are included in the income or loss under section 9. ... When a taxpayer receives an amount by virtue of or in connection with an office or employment, it is considered employment income under subsection 5(1). ... In another case when, for instance, an artist is selected by the Council for training or development through an arrangement under which the artist is placed under an employer for a small salary or no salary while the Council subsidizes the artist's employment income, the assistance from the Council to the artist, whether paid directly or through the employer, is considered to be received by virtue of the employment, and is therefore taxable in the artist's hands as income from employment. ...
Archived CRA website

ARCHIVED - General Income Tax and Benefit Guide - 2002

If you lived outside Canada on December 31, 2002, but maintained residential ties with Canada, you may be considered a factual resident of a province or territory. ... However, this may not apply if you were a factual resident who, under a tax treaty, is considered to be a resident of another country. ... Deemed resident- You are a deemed resident for tax purposes if you did not establish residential ties in Canada, but you stayed here for 183 days or more in 2002 and, under a tax treaty, you were not considered a resident of another country. ...
Archived CRA website

ARCHIVED - Patronage Dividends

A taxpayer is considered to qualify in "allocating in proportion to patronage" even though, for reasons of convenience, credit is not given to those customers to whom the patronage allocation would be less than $5.00, provided all other conditions are met. ... Payments may also be made in accordance with the terms and conditions of a contract, or in compliance with the terms of the taxpayer's charter, articles of association, or by-laws, which would not be considered to be patronage dividends. ... In all cases where payment has been effected by the payer in any manner whatsoever, the patronage dividend is considered to have been received by the customer. 15. ...
Archived CRA website

ARCHIVED - Dispositions of Cultural Property to Designated Canadian Institutions

However, if the taxpayer's legal representative applies in writing within that period to the Director of the local Revenue Canada tax services office, an extension of the period to what is considered reasonable in the circumstances may be granted. ¶ 5. ... If a gift is described in two or more of the categories of "total charitable gifts," "total Crown gifts," "total cultural gifts" or "total ecological gifts" made after February 27, 1995, it will be considered in the following order: a cultural gift, an ecological gift, a Crown gift, and a charitable gift. ¶ 8. ... The reader should, therefore, consider such comments in light of the relevant provisions of the law in force for the particular taxation year being considered, taking into account the effect of any relevant amendments to those provisions or relevant court decisions occurring after the date on which the comments were made. ...
Archived CRA website

ARCHIVED - Livestock of Farmers

Proceeds from the sale of livestock, including those animals in a basic herd, are by virtue of the definition of "inventory" in subsection 248(1) considered to be income if a taxpayer is in the business of farming (referred to as "farmer" in this bulletin). ... In the case of the basic herd, the cost to the beneficiary will be considered to be an amount equal to the fair market value at December 31, 1971 of the basic herd minus the amounts previously deducted by the deceased pursuant to section 29. 10. ... Where such a child receiving the property uses the livestock in the business of farming and computes income using the cash method, the child will be considered to have made a payment for the livestock equal to that fair market value and consequently may deduct this amount under paragraph 28(1)(e). ...
Archived CRA website

ARCHIVED - Income of contractors

In less formal situations where no construction contract exists or where the terms of a contract do not require formal approval of progress billings by the purchaser's architect or engineer before payment, the amount thereof, net of holdbacks if any, will be considered to be receivable and includable in the contractor's income as of the date such billings are made. 4. ... In contrast to 7 above, a cost is not considered to have been incurred in the performance of a contract in the year and is not deductible in the year in accordance with the comments in 6 above when it is, for example, (a) the cost of materials that have been merely ordered for future delivery, (b) the cost of materials and supplies that are described in a contractor's inventory, as that term is defined in subsection 248(1), including those earmarked for a specific contract but not delivered to the job site, (c) a holdback withheld by a contractor from a subcontractor if the contractor's liability to the subcontractor in respect thereof has not been established by the issuance of a required certificate by an architect or engineer, or (d) the gross amount of a billing rendered by a subcontractor to a contractor that requires, but has not received, approval prior to payment. 9. ... Where a person obtains a contract and agrees to sell to another person the right to carry out or complete the contract, the amount received on the sale is regarded as being in lieu of the profits expected to be earned had the contract been carried out in full, and therefore the amount is considered to be income. ...

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