Search - considered
Results 111 - 120 of 188 for considered
Ruling summary
2015 Ruling 2014-0550611R3 - Permanent Establishment -- summary under Article 5
Ruling ForCo will not be considered to carry on business through a permanent establishment, as defined in Article V of the Treaty, situated in Canada, solely as a consequence of the [described] activities of Employee performed in Canada…. ...
Ruling summary
2015 Ruling 2014-0541951R3 - Foreign Affiliate Debt Dumping -- summary under Subsection 212.3(3)
CRA ruled that Canco1 and Canco2 (at the top of the Canadian stack) will each be considered to be a QSC. ...
Ruling summary
2017 Ruling 2016-0670971R3 - Repayments of upstream loans and series test -- summary under Paragraph 90(8)(a)
Rulings Include that the repayments on the Forco2-FinanceCo1 Note will not be considered repayments made as part of a series of loans or other transactions and repayments for the purpose of s. 90(8)(a) or 90(14). ...
Ruling summary
2017 Ruling 2016-0655071R3 - Supplemental employee retirement plan -- summary under Subject Property of a Retirement Compensation Arrangement
CRA ruled that no portion of the distributed assets will be considered a “contribution” made to a retirement compensation arrangement (or the subject property of an RCA for the purposes s. 207.6(1) respecting the SERP Obligations assumed by Parent. ...
Ruling summary
2018 Ruling 2017-0683941R3 - Split-up transactions -- summary under Subsection 248(10)
This investment by Investor would have precluded s. 55(3)(a) treatment of the spin-off by virtue of s. 55(3)(a)(ii) if it had been considered to have occurred as part of the same series of transactions that included the deemed dividends arising on the spin-off cross-redemptions. ...
Ruling summary
2003 Ruling 2003-000498C - Qualifying disposition from trust to Sub -- summary under Paragraph 107.4(2)(a)
There will be no transfer of property to the Trust as consideration for the acquisition of a capital interest in the Trust where the particular property can reasonably be considered to have been received by the Trust in order to fund a distribution. ...
Ruling summary
2018 Ruling 2018-0749491R3 - 55(3)(a) Reorganization -- summary under Subsection 55(4)
The CRA tags mention s. 55(4) as a provision that it considered relevant: access to the s. 55(3)(a) exception was assisted by or depended on Parent controlling all the corporations involved in the transactions; the special voting shares of Parent likely had minimal economic attributes; and Parent’s will bequeathed them to the respective children. ...
Ruling summary
2019 Ruling 2018-0776381R3 - Part XIII tax under a reverse repo agreement -- summary under Paragraph 212(1)(b)
Ruling: The negative repo spread … will not be considered to be interest or an amount paid or credited as, on account or in lieu of, or in satisfaction of interest for the purposes of paragraph 212(1)(b) …. ...
Ruling summary
2021 Ruling 2021-0894621R3 F - Paiement à un membre qui quitte -- summary under Paragraph 3(a)
The CRA summary states that the “amount is considered to be a donation.” ...
Ruling summary
2021 Ruling 2020-0874961R3 - 55(3)(a) Internal Reorganization -- summary under Paragraph 55(3)(a)
CRA also ruled that s. 55(4) would not apply (which would have applied if it could reasonably be considered that one of the main purposes for father subscribing for special shares of the TCs was to cause them to continue to be related to DC so as to engage the s. 55(3)(a) exception), in light of a representation that father would continue to have high-level involvement in the TCs’ investing activities. ...