Search - considered

Such an agreement would also be considered to be a “debt security” and a “financial instrument”. ... Where a Dealer is actively involved in the loan application process and effects the financial institution’s supply of a financial service, the Dealer may be considered to be “arranging for” a financial service under paragraph (l) of the definition of financial service in subsection 123(1). ...

If it is determined that multiple supplies are being provided by a person the possible application of sections 138 and 139 should be considered. ... If the predominant element of the single supply is determined to be a financial service, then the supply as a whole will be considered a financial service. ...

In the case of certain travel and motor vehicle allowances, the public service body must ensure that: the allowance is reasonable for income tax purposes; and at the time the allowance was paid, the person considered it to be a reasonable allowance, and it was reasonable for the person to have considered it to be a reasonable allowance for income tax purposes. ...

In our view, a trust is considered to be governed by a registered pension plan if the trust holds all the property of a pension plan and is governed by its own written terms (i.e., trust agreement). ... In such circumstances, the employer would generally be considered to be making a supply of the relevant property or services to the trust, and sections 221, 225 and 228 would generally require a registrant employer to collect and remit GST/HST calculated on the consideration for the supply. ...

Such funding would be considered to be linked to the provision of RGI housing. Where an organization such as an [Administrator] has been determined to be a municipality pursuant to paragraph (b) of the definition of “municipality” in subsection 123(1) of the ETA, funding provided by such as organization will be considered acceptable funding if it is linked to the recipient’s provision of RGI housing within a program to provide housing to low-to-moderate-income households. ...

This policy statement assists in determining whether a particular activity may be considered “promotion” for the purposes of section 232.1, as well as whether an amount that has been paid, credited, or allowed as a discount by a supplier is an amount paid in return for the promotion of a product by a retailer for the purposes of section 232.1. It is our view that the Retailers’ provision of services to Distributor and/or Marketer, as described in the sample agreements summarized above, would be considered to be “promotion” for the purposes of section 232.1. ...

There is no evidence to suggest that there has been extensive development activities undertaken by the individual with respect to the land in this case, which much of Appendix C suggests is necessary in order for a sale to be considered as being made in the course of a business. ... The individual would also be considered to have made a deemed sale of the property under the change in use provisions of subsection 207(1). ...

Method accepted by Courts to be considered appropriate: Is it correct that an approach that has been accepted by the Courts will not be viewed as inappropriate for purposes of proposed subsection 141.02(7), even if an auditor disagrees? ... Method accepted by Courts to be considered appropriate An ITC allocation method that has been accepted by the Courts based on the current legislation (i.e., not based on proposed section 141.02), may still be found on an assessment of a QFI, to reflect inappropriateness and/or to otherwise not meet the requirements set out in proposed subsection 141.02(7) with respect to that QFI, so that it could not form the basis of a transitional year election under that subsection. ...

Prior to September 23, 2009, it is the CRA's administrative position as outlined in Technical Bulletin B-032, Registered Pension Plans, dated August 2011, that all property and services that are acquired or imported for use in activities relating to the plan trust assets, such as the holding or the investment of the assets, will be regarded as for the use in the plan trust's operation, and considered as Plan Trust Expenses. Property and services that are acquired or imported for use in activities related to the pension plan and not the plan trust assets will be regarded as having been acquired for use in the operation of the employer's business and considered Employer Expenses. ...

Where a nightly rate is used, each night is considered to be a period for GST/HST purposes. ... An amount paid to XXXXX that is not recorded in the XXXXX books and records as revenue would generally be considered to be a deposit until such time that XXXXX applies the amount as a payment for the supply and records the amount as revenue. ...