Search - considered

Your specific enquiry is whether, in the situation described above, X Co will be considered to have two taxation years both ending on April 30, 1990 or just one such year-end. ...

In any case, it is our understanding that such a mortgage would not be considered a bona fide mortgage for U.S. estate tax purposes and may therefore be ineffective in reducing such taxes. ...

You wish to know if the above payments would be considered to be income in the hands of the individual. ...

(Pursuant to paragraph 1. of your memo, even though Part B of the form was never completed and the conditions therein not satisfied, the certificate could still legally be considered a valid certificate). ...

Our Comments 21(1)(b) So far as we can determine, this issue has not been considered by the Courts. ...

As indicated in paragraph 6 of Interpretation Bulletin IT-212R3, inventory of an artist that is valued at nil pursuant to subsection 10(6) of the Act is considered to be a "right or thing" subject to the provisions of subsection 70(2) of the Act. ...

18 June 1991 Ministerial Letter 911338 F- Employee Benefit- Increase in Mortgage Rates as a Result of Relocation Unedited CRA Tags 6(9), 80.4(1), 110(1)(j), 248(1) Home relocation loan Dear Sirs: Re:  Subsection 6(9) and 80.4(1) This is in reply to your letter dated May 8, 1991 wherein you requested our technical interpretation as to whether an employee is considered to have received a benefit by virtue of subsections 6(9) and 80.4(1) of the Income Tax Act (the "Act") in light of the recent court decisions of R. ...

., would, in our view, be considered to be a "perquisite of the employment" similar to the situations discussed in paragraph 4 of IT-470R. ...

In the situation described, it is essentially a legal question whether a partner would be considered indebted to the MIC.  ...

Paragraph 7 of the bulletin lists several changes in respect of debt obligations which, when implemented, are considered to precipitate a disposition of the obligation.  ...