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In its decision, the court set forth three factors to be considered in determining whether a participating payment is deductible as interest, specifically the amount payable must-- Be considered compensation for the use of money;- Reference a principal amount; and- Accrue on a day-to-day basis. ... If the participating payment amounts are now considered interest, however, the payments will likely be subject to withholding tax. ... While the Sherway decision has caused the Department to expand our published position, it does not stand for the proposition that all participating payments are considered interest. ...

Position: both qualify if considered "carrying on business of farming" Reasons: def; in 110.6(1) XXXXXXXXXX D. ... On the other hand, an individual may be considered to be in the business of farming if a profit can reasonably be expected from the raising and exhibiting of horses. ... Basically one acre of land is considered to be part of the principal residence unless it can be proven that more is required. ...

Position: Generally explained each situation must be considered on its own through the local TSO. ... It clarifies that a dependant will not be considered financially depended if the dependant's income exceeds the specified limit unless a contrary position is established. ... It now reads as follows: "Financially dependent- for 1996, you are generally considered financially dependent on a deceased annuitant at the time of death if, prior to death, you ordinarily resided with and depended on the annuitant, and your net income (shown on line 236 of your return) for 1995 was $6,456 or less. ...

Question #1 Is a U.S. 401(k) pension plan considered a "foreign retirement arrangement" ("FRA") for purposes of the Income Tax Act (the "Act")? ... Consequently, a U.S. 401(k) pension plan is not considered an FRA for purposes of the Act. ... For the purposes of paragraph (c) above, investment income earned within an FRA is considered to derive from contributions to the FRA. ...

Rather you were considered as being a non-resident of Canada with certain Canadian source income which was taxable in Canada. ... Byrne in his letter of May 1, 1997, your disability income is considered to be income from a Wage Loss Replacement Plan for the purposes of the Act and is taxable pursuant to paragraph 6(1)(f) of the Act as income from an office or employment. Consequently, the disability payments you received resulted in your being considered, for the purposes of the Act, as having received income from being employed in Canada As also indicated to you by Mr. ...

Technical News #13 announced new guidelines that assist in the determination of whether employer-paid educational costs are to be considered a taxable benefit. ... Only training and educational costs which fall within the third category will be considered of primary benefit to the employee and thus remain taxable. ... The new guidelines will apply to individuals who received a taxable benefit in 1997, to determine whether the training is still considered taxable. ...

Would previous years of employment be considered for purposes of 60(j.1) calculation. 2. ... Thus, in our view, the amount paid by Subco to the employee will not be considered to be a retiring allowance. Rather, such an amount received would be considered an employment income which is not governed by the rollover rules under paragraph 60(j.1) of the Act. ...

In its decision, the court set forth three factors to be considered in determining whether a participating payment is deductible as interest, specifically the amount payable must-- Be considered compensation for the use of money;- Reference a principal amount; and- Accrue on a day-to-day basis. ... If the participating payment amounts are now considered interest, however, the payments will likely be subject to withholding tax. ... While the Sherway decision has caused the Department to expand our published position, it does not stand for the proposition that all participating payments are considered interest. ...

Position: both qualify if considered "carrying on business of farming" Reasons: def; in 110.6(1) XXXXXXXXXX D. ... On the other hand, an individual may be considered to be in the business of farming if a profit can reasonably be expected from the raising and exhibiting of horses. ... Basically one acre of land is considered to be part of the principal residence unless it can be proven that more is required. ...

You query whether the house would be considered completed in accordance with paragraph 12 of the Bulletin or whether completion would be deferred until the next fiscal period. ... Accordingly, it would appear that the contract would be considered "completed" for the purposes of the completion method. ... Such revenue would be considered to be included in computing income for tax purposes under subsection 9(1) of the Act. ...