Search - considered

Moreover, to be considered "split income", there must be a link between the income earned and allocated by the trust or partnership to the beneficiaries, and the business carried on by the related person. ... In order to be considered "split income" in the scenario presented, the rental income earned by the trust must be derived from property provided to, or in support of, a business carried on by the parent. ... Accordingly, the rental income earned by the trust would not likely be considered split income. ...

An impairment is considered to be prolonged if it has lasted, or is expected to last (from the time the disability begins), for a continuous period of at least 12 months. ... An individual's ability to perform a basic activity of daily living may also be considered to be markedly restricted where the performance of the basic activity of daily living requires an inordinate amount of time (significantly longer than for an average person). ... No other activity such as working, housekeeping or a social or recreational activity is considered a basic activity of daily living. ...

27 February 2004 External T.I. 2003-0051671E5- Convertible preferred shares- whether QI Unedited CRA Tags 146(1)(a R4900 R5100 Principal Issues: Whether convertible preferred shares and warrants to be issued by a particular corporation would be considered "qualified investments" for a trust governed by an RRSP. ... A share of the capital stock of an "eligible corporation" (as defined in subsection 5100(1) of the Regulations) may be considered a qualified investment if the conditions set out in paragraph 4900(6)(a) of the Regulations are met. The foregoing comments are meant to provide a brief summary of some of the provisions in the Act and Regulations under which a share constitutes a qualified investment for an RRSP trust and should not be considered either comprehensive or all-inclusive. ...

Reasons: They would be considered mortgage payments and not premiums. ... You have requested an interpretation on whether these mortgage payments can be considered a deductible premium pursuant to subsection 146(5) of the Income Tax Act (the "Act"). ... These payments are considered to be mortgage payments pursuant to the mortgage entered into between you and the RRSP and not premiums to an RRSP (as defined above). ...

5 October 2004 External T.I. 2004-0073631E5- Principal Residence-two condominiums Unedited CRA Tags 54 Principal Issues: Can two condomimiuns units be considered one single residence for purposes of the definition of "principal residence" in section 54 of the Act? ... Reasons: The two condominiums units are two separate legal properties, each of which would be considered housing units and each owned by a different spouse. 2004-007363 XXXXXXXXXX Karen Power, CA (613) 957-8953 October 5, 2004 Dear XXXXXXXXXX: Re: Principal Residence We are writing in reply to your letter of April 24, 2004, requesting our views on whether two separate condominium units may be considered a single "principal residence" under the Income Tax Act (the "Act"). ... The condominium units referred to in your letter are two separate legal properties (which would each be considered housing units) and would, in our view, be considered two properties for purposes of the definition of "principal residence" contained in section 54 of the Act. ...

Position: No Reasons: Even though the partners are considered to be carrying on the business of the partnership, the partnership interest cannot be considered to be property used by the partners for the purpose of gaining or producing income from a business. ... However, in our opinion, a partnership interest would not be considered property used by the partner for the purpose of gaining or producing income from the business carried on by him through the partnership. It is therefore our opinion that in the situation outlined in your letter the partnership interest is not considered qualified property for the purpose of paragraph 219(1)(l) of the Act. ...

Principal Issues: For purposes of calculating tax on excess foreign content pursuant to 206(2), when is a share that is foreign property considered to have been acquired, on the record date or the date the shares are delivered? Position: Shares are considered to be acquired on the date the shares are delivered. ... If a broker pays the vendor before the settlement date, this will be considered an advance only and the transaction will not be considered to be completed until the shares are delivered to the purchaser. ...

Principal Issues: Is the taxable benefit for premiums on a group long term disability insurance policy paid for by the employer on behalf of an employee considered a non-cash taxable benefit and therefore not insurable for EI purposes? ... 2) Are the premiums, paid for by the employer on behalf of an employee, on a GLTDIP considered a non-cash taxable benefit and, therefore, not insurable earnings for Employment Insurance ("EI") purposes even though they may have to be reported as employment income for salary reporting purposes? ... Generally, the taxable benefit for premiums, paid by an employer on behalf of an employee for disability insurance (including a GLTDIP), would be considered a non-cash benefit and subsequently not considered insurable earnings for EI purposes. ...

If the SA's were paid based on a percentage of gross profit, rather than sales, whether the amounts paid to them would be considered commission? ... If the SA's received a base salary in addition to an amount based on a percentage of sales, whether the latter portion would be considered a commission? ... Our comments As requested, we have considered your enquiry and have provided our views. ...

Since the employee cannot work in Canada without obtaining the work permit, and his family cannot enter Canada without a visa, these costs can be considered as part of the reasonable removal expenses. ... In our view, the costs incurred by an employee of obtaining a work permit and visas for his or her immediate family members would be considered part of the employee's reasonable relocation costs. ... Similarly, where the employer also pays for the cost of obtaining visas for the employee's spouse and children, this payment would not be considered a taxable employment benefit. ...