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Ministerial Letter

29 June 1990 Ministerial Letter 900318 - Provision pour marchandises à livrer et services ou à rendre

While the contract is spelled out in two seperate documents, the bill of sale and the credit note, the latter cannot be considered otherwise than as evidence of the conditions of the obligation to pay the balance of the purchase price. (...) ... The present case is, in my opinion, analogous to that considered (...) in Time Motors Limited V. ... If so, then the amount must be considered a contingent liability and therefore not deductible under paragraph 18(1)(e) of the Act. ...
Ministerial Letter

12 March 1997 Ministerial Letter 9702398 - DISABILITY/SURVIVOR PENSIONS RELATED TO WAR ACTIVITY

Is this type of war disability pension considered to be income for tax purposes? ...
Ministerial Letter

21 March 1997 Ministerial Letter 9702488 - HERITAGE BUILDINGS - TAX POLICY ISSUES

Accordingly, any changes to tax policy or amendments to the legislation would have to be considered by that department. ...
Ministerial Letter

21 October 1997 Ministerial Letter 9723338 - VACATION TIMESHARING XXXXXXXXXX

In establishing intent, various factors, including the vendor's promotional literature, the way the purchase is financed, and the purchaser's subsequent actions with respect to the investment, are considered. ...
Ministerial Letter

25 May 1994 Ministerial Letter 9408238 - EMPLOYMENT INCOME OF STATUS INDIAN EMPLOYEES

The central management and control of an organization is normally considered to be exercised by the group that performs the function of a Board of Directors of the organization. ...
Ministerial Letter

13 December 1994 Ministerial Letter 9420998 - GOVERNMENT OFFICIAL PERKS

The travelling expenses of a member's family, including a nanny who cares for the member's child or children, would be considered a personal expense of the member even if the member was travelling on government business for that particular trip. ...
Ministerial Letter

15 November 1996 Ministerial Letter 9624938 - AUDITOR GENERAL'S REPORT ON FAMILY TRUSTS

Those issues were considered by the House of Commons Standing Committee on Finance in its report released on September 18, 1996. ...
Ministerial Letter

17 February 1995 Ministerial Letter 5M11338 - SOURCE DEDUCTION REQUIREMENTS

Principal Issues: Whether TD1 can be used claim that employment income will be exempt under the Indian Act and remove employer's responsibility to remit source deductions Position: Potential non-taxability of income does not remove requirement for source deductions Reasons: Personal credits are considered for TD1 purposes but not statutory exemptions. ...
Ministerial Letter

5 January 1996 Ministerial Letter 9533018 - INDIANS - SCHOOL DISTRICT XXXXXXXXXX

Brooks, you stated that the affected employees have previously been considered by the School District to be tax-exempt. ...
Ministerial Letter

23 December 1999 Ministerial Letter 9931938 - GIFT OF REAL PROPERTY BY NON-RESIDENT

We further understand that the Department of Finance considered it unnecessary to prescribe the Trust for this purpose since it is a Canadian registered charity and therefore United States donors of taxable Canadian property to the Trust may already elect under subsection 118.1(6)(a) of the Act. ...

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