Search - considered

Position: It is a question of fact, but no if the work location is considered to be the employee's RPE. ... Travel between the employee's home and a regular place of employment is considered to be personal travel. ... Where an employee works at a particular location for an extended period of time such place will most likely be considered to be that employee's regular place of employment. ...

Position: A number of factors need to be considered in determining whether a particular plan is a SERP or an SDA. ... Accordingly, to determine if a particular arrangement is an SDA, all of the terms of the particular arrangement must be considered. ... What are the CRA's views on whether such plans could be considered salary deferral arrangements (SDAs)? ...

At issue is whether CC would be required to reduce its otherwise eligible SR&ED expenditures by virtue of subsection 127(18) for a portion of the government assistance on the basis that a portion of the assistance "can reasonably be considered to be in respect of" SR&ED. ... Subsection 127(18) of the Act applies to reduce qualified expenditures where the government assistance, non-government assistance or contract payment "can reasonably be considered to be in respect of" SR&ED. ... Whether an amount "can reasonably be considered to be in respect of" SR&ED in a particular situation is a question of fact to be determined with reference to the circumstances, agreements, etc., relevant to the particular situation. ...

Position: A number of factors need to be considered in determining whether a particular plan is a SERP or an SDA. ... However, the CRA has taken the position that a plan will not be treated as an SDA where the plan has the characteristics of an unregistered or supplementary pension plan and the amounts that may be paid out of or under the plan can be considered to be reasonable superannuation or pension benefits. ... Where a specific arrangement provides benefits that are not the same as those provided under the registered plan, or are greater than those that could be provided under the registered plan (but for the defined benefit or money purchase limit), then the terms of the arrangement and any other relevant information must be considered to determine if the benefits are reasonable in order to ensure that the plan or arrangement will not be considered an SDA. ...

Accordingly, it would be considered to be earned in the normal economic mainstream, and thus not considered personal property on a reserve. ... Although this is one factor that must be considered in determining whether such interest is exempt from taxation, other factors must also be considered. ... Because such income may be generated off the reserve or by non-Indians, it would be considered to be earned in the normal economic mainstream and, accordingly, not considered personal property situated on a reserve. ...

As it appears that the transaction in question (i.e. the sale of shares of Parent Co.) has been completed, a request for an advance income tax ruling would not be considered. ... The question to be addressed is whether the building, while under construction, would be considered an asset “used principally in an active business”. ... The issue of whether property was used or held by a corporation in the course of carrying on a business was considered by the Supreme Court in Ensite Limited v. ...

Accordingly, the loan would be considered as assistance. As well, if the lender is committed to forgive the loan because of insufficient revenue or for any other reason, the loan would be considered to be a forgivable loan. ... Your concern would appear to be whether the funding would be considered "assistance", for the purposes described above. ... An amount paid to a production company that otherwise would be described under subparagraphs 12(1)(x)(i) to (iv) of the Act may not necessarily be considered as assistance. ...

If the training falls into category 1 or 2 it will be considered non-taxable. Category 3 training will be considered taxable. Each case must be examined. ... As such, benefits paid out of the TTF would not be considered taxable under 6(1)(g) of the Act. ...

Accordingly, it would be considered to be earned in the normal economic mainstream, and thus not considered personal property on a reserve. ... Although this is one factor that must be considered in determining whether such interest is exempt from taxation, other factors must also be considered. ... Because such income may be generated off the reserve or by non-Indians, it would be considered to be earned in the normal economic mainstream and, accordingly, not considered personal property situated on a reserve. ...

As it appears that the transaction in question (i.e. the sale of shares of Parent Co.) has been completed, a request for an advance income tax ruling would not be considered. ... The question to be addressed is whether the building, while under construction, would be considered an asset “used principally in an active business”. ... The issue of whether property was used or held by a corporation in the course of carrying on a business was considered by the Supreme Court in Ensite Limited v. ...