Search - considered

Filter by Type:

Results 12471 - 12480 of 49528 for considered
Technical Interpretation - External

2 November 1990 External T.I. 9022615 F - Salary Deferral Arrangements

It is our general view that where an employer agrees to pay an employee an amount on or after his retirement and the amount cannot reasonably be considered to be salary for services rendered that the employee agreed to defer receipt of, the amount will not be considered to be a payment out of a salary deferral arrangement. Whether such an amount would be considered to be a retiring allowance as defined in the Act can only be determined by reference to the facts of the particular case. ...
Miscellaneous severed letter

7 April 1991 Income Tax Severed Letter - Tax implications of travel between an employee's home and regular work location

7 April 1991 Income Tax Severed Letter- Tax implications of travel between an employee's home and regular work location Unedited CRA Tags none Dear XXX I am writing in response to your letter of March 11, 1991, regarding concerns XXX Travel between an employee's home and regular work location is considered personal commuting, the costs of which are not considered a deductible travelling expense. The employer's place of business is considered to be the place where the employee usually works for his employer. ...
Miscellaneous severed letter

7 November 1990 Income Tax Severed Letter - Salary deferral arrangements

It is our general view that where an employer agrees to pay an employee an amount on or after his retirement and the amount cannot reasonably be considered to be salary for services rendered that the employee agreed to defer receipt of, the amount will not be considered to be a payment out of a salary deferral arrangement. Whether such an amount would be considered to be a retiring allowance as defined in the Act can only be determined by reference to the facts of the particular case. ...
Miscellaneous severed letter

18 April 1991 Income Tax Severed Letter 91-2424T F - Deductible Travelling Expenses

Research File Subject or Corporate Case FileReturn to Rulings, Room 303, Metcalfe Building                                   April 18, 1991Dear 19(1) I am writing in response to your letter of March 11, 1991 regarding concerns   24(1) Travel between an employee's home and regular work location is considered personal commuting, the costs of which are not considered a deductible travelling expenses.  The employer's place of business is considered to be the place where the employee usually works for his employer 24(1) The Income Tax Act does not contain a provision to provide the tax assistance that your constituents desire.  ...
Miscellaneous severed letter

2 November 1990 Income Tax Severed Letter

It is our general view that where an employer agrees to pay an employee an amount on or after his retirement and the amount cannot reasonably be considered to be salary for services rendered that the employee agreed to defer receipt of, the amount will not be considered to be a payment out of a salary deferral arrangement. Whether such an amount would be considered to be a retiring allowance as defined in the Act can only be determined by reference to the facts of the particular case. ...
Miscellaneous severed letter

18 April 1991 Income Tax Severed Letter

Research File Subject or Corporate Case File Return to Rulings, Room 303, Metcalfe Building April 18, 1991 19(1) Dear 19(1) I am writing in response to your letter of March 11, 1991 regarding concerns 24(1) Travel between an employee's home and regular work location is considered personal commuting, the costs of which are not considered a deductible travelling expenses. The employer's place of business is considered to be the place where the employee usually works for his employer 24(1) The Income Tax Act does not contain a provision to provide the tax assistance that your constituents desire. ...
SCC

Mattabi Mines Ltd. v. Ontario (Minister of Revenue), [1988] 2 CTC 294, [1988] 2 S.C.R. 175

Conversely, if non-taxable income is not to be considered “income” for the purposes of subsection 106(1), it should also be excluded from the "incomes" referred to in subsection 106(5). ... The Department's views may be helpful in the interpretation of certain phrases used in the opening words of subsection 18(1) and in paragraph 18(1)(a), but it should be remembered that these phrases must also be considered in relation to the wording of the paragraph as a whole. ... Deputy Minister of Revenue of Quebec, [1978] 1 S.C.R. 851; [1977] C.T.C. 441; this fact was recognized in a case in which Quebec considered a lump sum payment to be taxable as such while the federal government treated it as eligible for forward averaging. ...
TCC

Brenneur v. The Queen, 2010 TCC 610

However, the competing, conflicting issue to be considered is whether joining Mr.  ...   [31]          The respondent has suggested that, and this Court has considered whether, interpreters could be used effectively and efficiently, in the hearing of the reference of common questions, to protect Mr.  ... Batalha nor even proposed to him in writing that he should be reassessed or indicated that he was being considered for reassessment. ...
TCC

Duthie Estate v. MNR, 92 DTC 1043, [1992] 1 CTC 2099 (TCC)

The three alternatives considered by Dr. Duthie and his associates were described as follows by Mr. ... Having regard to this finding, the first question that needs to be considered is whether the expenses incurred by Dr. ... It seems to me that all of the expenditures relating to the investigation of opportunities must be considered on the same footing. ...
FCTD

Woodward Stores Ltd. v. The Queen, 91 DTC 5090, [1991] 1 CTC 233 (FCTD)

Courts have also repeatedly stated that the classification of receipts or expenditures into capital or income depend on all the surrounding facts and circumstances of each case, judicial precedents being no more than guidelines to a court to make sure that all material and relevant facts are considered or analyzed. ... Otherwise, depending on the circumstances, the amount received may be considered to be either a reduction of rental expense or a Capital receipt to the tenant. This bulletin was modified on December 20, 1983, such that paragraph 9 of IT-359R2 now reads as follows: A payment received by a tenant from a landlord as an inducement to enter into a lease will be considered in the hands of the tenant as (a) a non-taxable capital receipt where the payment is a reimbursement of part or all of the tenant's capital cost of leasehold improvements within the meaning of Regulation 1102(4); (b) a reduction of those expenses where the payment is a reimbursement of other expenses incurred by the tenant; (c) income where the negotiation of leases is a regular part of the tenant's business operations (eg. a chain store); (d) a reduction of what would otherwise be the rental expense of the tenant where the payment is a rebate of rent for a period of the lease; (e) a non-taxable capital receipt in other cases. ...

Pages